I was reading this review on Amazon for a recessed outlet where someone points out that it isn't tamper resistant and, as such, is worthless. There is a discussion between the rater and other people (including a Leviton rep) about this comment. Someone points out that there is an exception for when there's an appliance that isn't easily moved in the way of the outlet. There's also an exception if it is mounted 6 (or is it 5.5) feet high. Contrary to what the Leviton rep suggests, most people do not mount there TV 6 feet high so that exception goes out the window very quickly. On the other hand, it would be extremely difficult for a toddler to get their fingers in the outlet behind a mounted TV so I would think the TV blocking the outlet should qualify for the exception. However, I don't think many people, in everyday language, would call a TV an appliance so I was wondering how this would shake out.
This could be a tricky one, as it depends on what you consider an "appliance", and how you define "dedicated space".
National Electrical Code 2014
Chapter 4 Equipment for General Use
Article 406 Receptacles, Cord Connectors, and Attachment Plugs (Caps)
406.12 Tamper Resistant Receptacles.
(A) Dwelling Units. In all areas specified in 210.52, all nonlocking-type 125-volt, 15-and 20-ampere receptacles shall be listed tamper-resistant receptacles.
Exception to (A), (B), and (C): Receptacles in the following locations shall not be required to be tamper-resistant:
(1) Receptacles located more than 1.7 m (5 1⁄2 ft) above the floor.
(3) A single receptacle or a duplex receptacle for two appliances located within dedicated space for each appliance that, in normal use, is not easily moved from one place to another and that is cord-and-plug connected in accordance with 400.7(A)(6), (A)(7), or (A)(8).
Easy peasy if the receptacle is 5 1/2' above the floor. A bit confusing otherwise. First you have to decide if a TV meets the NEC definition of an appliance.
Appliance. Utilization equipment, generally other than industrial, that is normally built in standardized sizes or types and is installed or connected as a unit to perform one or more functions such as clothes washing, air conditioning, food mixing, deep frying, and so forth.
Sure, I guess.
Next, you have to determine if the receptacle is located within the dedicated space for the TV. This is made difficult, as NEC doesn't define "dedicated space" well.
110.27(E)(1)(a) Dedicated Electrical Space. The space equal to the width and depth of the equipment and extending from the floor to a height of 1.8 m (6 ft) above the equipment or to the structural ceiling, whichever is lower...
110.27(E)(2)(b) Dedicated Equipment Space. The space equal to the width and depth of the equipment and extending from grade to a height of 1.8 m (6 ft) above the equipment, shall be dedicated to the electrical installation.
Based on these definitions, I'd say the receptacle is likely not within the dedicated space for the appliance.
Unless there's a local ammendment to the code that makes it more clear, I'd say this is a judgement call for the Authority Having Jurisdiction. For the price difference between a TR receptacle and non TR receptacle, I'd probably just install a TR receptacle.
Where do you live? In Oregon non tamper outlets and non GFCI's are allowed behind an appliance not easily moved. in section 100 of the NEC an appliance is
utilization equipment, generally other than industrial, that is normally built in standard shapes or sizes or types and is installed or connected to preform one or more functions.
It gives some standard examples, but a TV is utilizing power so it meets the definition. New construction requires most outlets to be Tamper resistant this is true, but if this is an older house you can still buy and replace 2 wire non grounded receptacles and be totally code compliant. In the review the OP was a bit over the edge since the product was not advertised as tamper resistant. I would use the non tamper recessed outlet here in Oregon because it is for a dedicated use behind the equipment not easily moved.