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We're working with a design-build firm, doing a gut reno on our primary bath. We purchased a Watermark TWRD3-24 electric towel rack (it's a set of 3 individual heated bars, specs and instructions here), which they've included in the designs for months (see below).

Just before work started, they told us that because of the distance from the tub to the towel rack is <24", it needed to have an IP rating of at least IPX4. The product has been discontinued, so I contacted the company to see if they had an IP rating, and they called the original manufacturer and said it is rated IP56. However, after weeks of back and forth, they told us they cannot provide any documentation for that rating (Watermark no longer works with the manufacturer so it seems the manufacturer doesn't care).

We passed the electrical rough in inspection while I was trying to get some kind of documentation, but now that I've struck out it seems that we have paid a lot of money for a very nice (yet impractical) paperweight. We're a bit pissed that our contractor didn't either look into the compliance of the towel rack or let us know that it needed to have an IP rating before we selected and ordered it.

So, now the question is, do we just have to give up? I've looked for alternative heated towel racks, and many of them don't say anything about IP rating on their spec sheets, which seems odd for something that is supposed to go in bathrooms. Some models have things like "IP55 cord" (these are hardwired not plug-in models), but don't list an overall IP rating.

If they did get an IP rating, presumably they got it through some certifier or something --- is there any way to look up a rating in some certification database or something? The instructions do say "UL499 certified" and "In compliance with 2014/35/UE DIRECTIVE", but I assume neither of those signify compliance with the IP requirement. What sort of documentation does the inspector need?

Hoping there's a magical solution out there!

Electrical plan for bathroom

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    Can they be moved? Will electrical move cost more than the warmers? Main problem seems to be too close to the tub(less than 24") where greater than 24 inches is good. Contractor might cover some of the new wall work, if they are nice.
    – crip659
    Nov 26, 2023 at 21:04
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    Can you shoot a photo of the UL Listing logo that is on the physical article itself? It should have a 5-8 digit file number nearby. Only search the towel rack proper; I don't want to hear about anything in documentation or advertisements. CSA or ETL is a substitute for UL. Nov 26, 2023 at 21:11
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    If they had subjected the heaters to specialized testing under a standard, then they would have bragged about it. IPX4 testing involves spraying the thing with water under a test protocol. Your heaters are not conformant.
    – popham
    Nov 26, 2023 at 21:42
  • @Harper-ReinstateMonica I checked and I can’t see a UL logo on the towel warmers; is it possible it would be on the interior?
    – bwk
    Nov 27, 2023 at 2:11
  • @crip659 Unfortunately there's no wall space where it would be more than 24" from the tub
    – bwk
    Nov 27, 2023 at 2:14

2 Answers 2

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Ask your contractor to specify exactly which regulation requires that IPX4 rating. Keep in mind that NKBA is not a legally mandated certification, so if the contractor says that it's an NKBA thing, it doesn't actually matter.

The only codes that probably matter in your case are the electrical code and the building code, and I don't think either of those codes concern themselves with IPx water and dust ratings, they only are concerned with Nationally Recognized Testing Laboratories (NRTLs) like UL, Intertek, TUV, CSA Group Labs, etc.

The NRTL (in this case UL) certifies the appliance for use in a particular location. This could be a wet location, a dry location, a hazardous location, or an unclassified location. UL499 certifies heating appliances in unclassified locations, so my guess this could be the reason the contractor is saying it's not allowed a certain distance from the shower.

If you're willing to purchase a different towel rack, don't look for one with a specific IP rating, look for one with a UL (or other NRTL) WET LOCATION rating.

Additionally, the electrical code will determine what kind of circuit is needed (GFCI protection almost certainly) and an electrician should be able to help with that.

P.S. I just googled "heated towel rack with UL wet location rating" and a bunch came up. They are pretty expensive though!

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    The only other thing that I would add is, technically, manufacturer directions trump almost all codes. So if the manufacturer passed UL certification for unclassified locations, and the manufacturer of the rack puts in writing that it can be used with 24" of a shower or tub, that actually means it's allowed. But that can be a difficult conversation to have with an inspector. Nov 26, 2023 at 23:13
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Strongly suggest moving it away from the tub.

Take a step back, and consider: why are the electrical code restrictions there to begin with? I know a retired building inspector, who has told me that most of the code rules are there because someone died.

What could go wrong, when you, a loved one or a guest is climbing out of the tub? I'll bet you that sooner or later, someone is going to (maybe slip and) use the towel rack for a grab-bar, resulting in:

  • Pulling it off the wall, and/or
  • Wires being pulled out of junctions or heaters, and perhaps contacting the (presumably conductive) casing. Now the person climbing out of the tub (which has a perhaps-grounded drain pipe, or at least a trail of moisture) is directly in the path of AC current.

Is having the towel bar right there worth the risk?

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  • When you read some of the regs (based on what has happened as your inspector pointed out) one does think "why are some people so stupid that we have to make a regulation for this"?
    – Solar Mike
    Nov 28, 2023 at 7:00
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    While some regs are the result of people making very questionable choices, someone inadvertently using a towel-rail as a grab bar, especially if elderly or mid-fall, certainly seems very likely. Nov 28, 2023 at 7:30
  • @SolarMike One factor distraction (think 'texting while driving'). The conscious parts of our brains don't multi-task; we can do ONE activity requiring conscious thought at a time well. Try to do two (e.g. texting while driving) and that gets demonstrated. Another factor is different types or areas of intelligence; to name a few, a great leader and speaker who can motivate people may be clueless about mechanical or electrical systems. And then we have children, teenagers, elderly, and the semi-awake adults, as well as the ignorant and confused. Generally frowned upon to kill them off. Nov 28, 2023 at 18:39
  • The above scenario is the reason that GFCI protection would be required on the circuit. In wet locations, GFCI protection is mandated. It shuts the power off immediately if the current in the circuit is finding a path to ground that is abnormal (such as through a person standing in an electrified puddle of water). Nov 30, 2023 at 3:53
  • Another thought: how structurally sound is the towel rack and its mounting? If it's placed such that it ends up being used as a grab bar (I don't know whether the intended placement would make this the case), it should be sufficiently strong, including its mounting, to be used as a grab bar. Dec 1, 2023 at 23:53

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