Restrict Tenant Access to Panel

[915Ben]

Hello all,

I am working on an apartment remodel design where each apartment currently has a mech/elec room which houses a furnace, water heater, and electrical panel. The room has working space for all these items which the tenants have turned into storage space. The owner has asked if we can simply put a lock on the room and deny the tenants access. Going through the code I have found 110.26(G) which tells me that a locked electrical room is considered accessible to qualified persons but then I see 240.24(B) which states that all occupants (not just the qualified ones) are required to have access to overcurrent devices serving branch circuits in the occupied space. Here is where my confusion begins, 240.24(B)(2) states:

"Where electric service and electrical maintenance are provided by the building management and where these are under continuous building management supervision, the branch circuit overcurrent devices suppling any guest rooms or guest suites whith out permanent provisions for cooking shall be permitted to be accessible only to authorized personnel."

In my case I think it is pretty clear that I cannot have the panel locked away from the tenants but from this section of code, it appears to me that the only spaces in the entire world of occupied spaces that can have restriced breaker access are guest rooms and guest suites without cooking appliances. Unless I am missing something, that means that every locked electrical panel in every commercial building is in violation of 240.24(B). Is there another section of code I am missing that negates the requirements of 240.24(B) or are branch circuit breakers intended to be accessible to anyone who occupies a space? If the latter case is the intention of the code, how does one square that with hospitals, or asylums, or prisons? Any thoughts?

Thanks

 

[kwired]

Hello all,

I am working on an apartment remodel design where each apartment currently has a mech/elec room which houses a furnace, water heater, and electrical panel. The room has working space for all these items which the tenants have turned into storage space. The owner has asked if we can simply put a lock on the room and deny the tenants access. Going through the code I have found 110.26(G) which tells me that a locked electrical room is considered accessible to qualified persons but then I see 240.24(B) which states that all occupants (not just the qualified ones) are required to have access to overcurrent devices serving branch circuits in the occupied space. Here is where my confusion begins, 240.24(B)(2) states:

"Where electric service and electrical maintenance are provided by the building management and where these are under continuous building management supervision, the branch circuit overcurrent devices suppling any guest rooms or guest suites whith out permanent provisions for cooking shall be permitted to be accessible only to authorized personnel."

In my case I think it is pretty clear that I cannot have the panel locked away from the tenants but from this section of code, it appears to me that the only spaces in the entire world of occupied spaces that can have restriced breaker access are guest rooms and guest suites without cooking appliances. Unless I am missing something, that means that every locked electrical panel in every commercial building is in violation of 240.24(B). Is there another section of code I am missing that negates the requirements of 240.24(B) or are branch circuit breakers intended to be accessible to anyone who occupies a space? If the latter case is the intention of the code, how does one square that with hospitals, or asylums, or prisons? Any thoughts?

Thanks

It is a little different with dwelling units than it is for hospitals, prisons, or other similar areas. A dwelling or even a commercial space in a multiple occupant building needs to have access for the regular users of the space, unless there is also a third party responsible and always available for taking care of issues that may require access to such equipment.

Hospitals, asylums, prisons, hotels, etc. are more transient type of occupants outside of the staff of the facility. Not everyone needs access to electrical/mechanical equipment, and in fact there could even be safety or security issues in some cases if access was readily available to anyone.

 

[Gregg Harris]

If the latter case is the intention of the code, how does one square that with hospitals, or asylums, or prisons? Any thoughts?

In these scenarios there would be an on site building engineer to attend to any problems

 

[kwired]

If the latter case is the intention of the code, how does one square that with hospitals, or asylums, or prisons? Any thoughts?

In these scenarios there would be an on site building engineer to attend to any problems

Engineer, probably not. Just any staff available that has access is enough. In the case of a hospital a lot may depend on the size of the facility. I do work for a small 10 patient room hospital that only has a couple nurses on duty in the wee hours of the morning. If something goes wrong they do what they can or call someone - usually a maintenance person that is employed by the hospital is first one to call. They certainly don't want to make a circuit failure in a patients room become the patients problem to resolve and the NEC does not intend for this either.

Similar event in an apartment building - if there is a problem the tenant either has access to his overcurrent devices so he can reset them, or the facility needs to have some kind of attendant to contact (typically at least on site) even if that attendant is not the person that will perform whatever task is necessary.

 

[GoldDigger]

If the latter case is the intention of the code, how does one square that with hospitals, or asylums, or prisons? Any thoughts?

In these scenarios there would be an on site building engineer to attend to any problems

Speaking of prisons, the issue of locked electrical panels seems to come up often in college dorms and similar residences. The panel keys are often held by the Resident Assistants who are usually available, but sometimes it takes a call to Security to get a breaker turned back on. Is that considered part of building management? I.E. "where these are under continuous building management supervision,"?

 

[915Ben]

It is a little different with dwelling units than it is for hospitals, prisons, or other similar areas. A dwelling or even a commercial space in a multiple occupant building needs to have access for the regular users of the space, unless there is also a third party responsible and always available for taking care of issues that may require access to such equipment.

Hospitals, asylums, prisons, hotels, etc. are more transient type of occupants outside of the staff of the facility. Not everyone needs access to electrical/mechanical equipment, and in fact there could even be safety or security issues in some cases if access was readily available to anyone.

I agree with your reasoning but the code does call for "occupants" to have access, not just qualified persons or regular users. In the case of my apartments there actually is a safety issue with the tennants refusing to abide by the management and storing junk in front of electrical panels. Also, not originally mentioned, is that the maintenance man lives on site which makes things even more fuzzy. I guess the point of my posting was to reassure myself that this is kind of a grey area / judgement call to be made by the AHJ and there is no clear cut part of the code spelling out the rules.

 

[GoldDigger]

I agree with your reasoning but the code does call for "occupants" to have access, not just qualified persons or regular users. In the case of my apartments there actually is a safety issue with the tennants refusing to abide by the management and storing junk in front of electrical panels. Also, not originally mentioned, is that the maintenance man lives on site which makes things even more fuzzy. I guess the point of my posting was to reassure myself that this is kind of a grey area / judgement call to be made by the AHJ and there is no clear cut part of the code spelling out the rules.

The non-electrical code side of the issue is what steps the landlord can take when stuff is stored inside clearly marked (they are marked aren't they?) access spaces around equipment. Can they just remove the offending property and lock it up somewhere else?

 

[915Ben]

The non-electrical code side of the issue is what steps the landlord can take when stuff is stored inside clearly marked (they are marked aren't they?) access spaces around equipment. Can they just remove the offending property and lock it up somewhere else?

I think that is what is going to happen in the end. I just had the architect question if locking the room is an option.

 

[ramsy]

I just had the architect question if locking the room is an option.

Fire code requires main-disconnect access.
Disconnects must usually be accessible to Fire/Safety personnel.
Tenant meter/disconnects are usually located separate from unit fuse boxes.

If your locked closets won't include main disconnects, you should be OK with fire code.
Many commercial/industrial meter closets are locked for Authorized Persons only, not sure about tenant space.

In practice the POCO typically demands a key/lock-box combo for any locked-meter rooms.
You may need written authorization from the AHJ to lock meter/DC's in tenant spaces.

 

[kwired]

Speaking of prisons, the issue of locked electrical panels seems to come up often in college dorms and similar residences. The panel keys are often held by the Resident Assistants who are usually available, but sometimes it takes a call to Security to get a breaker turned back on. Is that considered part of building management? I.E. "where these are under continuous building management supervision,"?

Just because security, maintenance, or whoever is on duty is not in the same building doesn't mean someone isn't on duty to perform such a task on a campus type facility, which could include colleges, hospitals, prisons, etc.

I agree with your reasoning but the code does call for "occupants" to have access, not just qualified persons or regular users. In the case of my apartments there actually is a safety issue with the tennants refusing to abide by the management and storing junk in front of electrical panels. Also, not originally mentioned, is that the maintenance man lives on site which makes things even more fuzzy. I guess the point of my posting was to reassure myself that this is kind of a grey area / judgement call to be made by the AHJ and there is no clear cut part of the code spelling out the rules.

Inspection at the time the structure is built is not the same as complying with those rules by the occupants down the road. If there is no authority enforcing any rules to keep this space clear, sure looks like a good place to store things to almost anybody, except electrical professionals:happyyes:

Fire code requires main-disconnect access.
Disconnects must usually be accessible to Fire/Safety personnel.
Tenant meter/disconnects are usually located separate from unit fuse boxes.

If your locked closets won't include main disconnects, you should be OK with fire code.
Many commercial/industrial meter closets are locked for Authorized Persons only, not sure about tenant space.

In practice the POCO typically demands a key/lock-box combo for any locked-meter rooms.
You may need written authorization from the AHJ to lock meter/DC's in tenant spaces.

Even if a panelboard is in a space easy to get to, code does not prohibit having padlocks on panel covers or breaker locks or disconnect switch locks. If fire department wants to shut a disconnect or breaker off they have cutters to remove a lock pretty quickly and will not hesitate to use them. Same goes for opening a locked mechanical room door.

 

[ramsy]

code does not prohibit having padlocks on panel covers or breaker locks or disconnect switch locks.

NFPA-70 230.7(A)(1) & 230.92 prohibits locking both at the same time.

 

[iwire]

NFPA-70 230.7(A)(1) & 230.92 prohibits locking both at the same time.

What year?

 

[kwired]

NFPA-70 230.7(A)(1) & 230.92 prohibits locking both at the same time.

Which edition? 2011 230.7 has nothing to do with locking anything. 230.92 has to do with tenant access to service disconnecting means, and an alternate solution if it is not accessible to the tenant, and not the locking of a panel or devices within a panel that is accessible to a tenant.

 

[102 Inspector]

Along with panel access, have proper clearances to the furnace and water heater been maintained. Are they gas appliances where combustion air might be restricted to the appliance. I would suggest posting it on the lease agreement that the room is not to be used for storage of any knid and a penalty if found obstructed. Tell occupant to get rid of some of their stuff.

 

[ramsy]

What year?

2011, 2008, and 2005 NFPA-70 230.70 and 230.92

 

[ramsy]

..230.92 has to do with tenant access to service disconnecting means, and an alternate solution if it is not accessible to the tenant, and not the locking of a panel or devices within a panel that is accessible to a tenant.

230.92 established that "locked or sealed" is not readily accessible, as required by both sections.