Circuit Breakers Required to be Below 48" for ADA Accessibility???

[sparkyrick]

I just ran into a problem with an inspector that said my panels were mounted too high (6' to top of a Sq D 42 space resi style panel). He said that ALL circuit breakers feeding general purpose receptacles and lighting need to be below 48" to meet ADA. This would put the panel about 2' off the floor. I've never heard of this. Is he interpreting the ADA requirements correctly???

 

[GoldDigger]

I just ran into a problem with an inspector that said my panels were mounted too high (6' to top of a Sq D 42 space resi style panel). He said that ALL circuit breakers feeding general purpose receptacles and lighting need to be below 48" to meet ADA. This would put the panel about 2' off the floor. I've never heard of this. Is he interpreting the ADA requirements correctly???

Is the facility one which is covered by ADA?
If so, see this link.
There you will find:

205.1 General. Operable parts on accessible elements, accessible routes, and in accessible rooms and spaces shall comply with 309.

EXCEPTIONS: 1. Operable parts that are intended for use only by service or maintenance personnel shall not be required to comply with 309.

and

309 Operable Parts

309.1 General. Operable parts shall comply with 309.

309.2 Clear Floor Space. A clear floor or ground space complying with 305 shall be provided.

309.3 Height. Operable parts shall be placed within one or more of the reach ranges specified in 308.

308 basically says 48" max if there are no obstructions keeping a wheelchair from pulling up next to the wall. Lower if there are obstructions.
I think that there is ample support for the inspectors position, with room for dispute about whether the panel is an accessible element in an accessible room and whether it meets the exception to 205.1. But that is limited in turn by:

Advisory 205.1 General. Controls covered by 205.1 include, but are not limited to, light switches, circuit breakers, duplexes and other convenience receptacles, environmental and appliance controls, plumbing fixture controls, and security and intercom systems.

This definitely shows that circuit breakers are operable parts, but may not totally remove the opportunity to apply the Exception.

No, I have not seen this enforced, but there are a lot of things I have not seen. And if you want to dispute the inspector's finding you will need more than a quick reading of the standard to support you.

PS: The 48" would be to the highest control which is required to be accessible. That will probably include the Main. But not to the top of the panel or even the panel door.

 

[infinity]

You said residential, is this housing for handicapped people?

 

[sparkyrick]

Here is a little more info, this is a new dental clinic.

 

[infinity]

Here in NJ (we have a separate State written ADA code) the requirement would only apply if during the normal course of business someone who is handicapped would need to operate that circuit breaker. I would still think that even under the federal ADA the inspector is wrong otherwise a panel would need to be mounted on the floor and what if exceeded 48"?

 

[sparkyrick]

PS: The 48" would be to the highest control which is required to be accessible. That will probably include the Main. But not to the top of the panel or even the panel door.

Yeah, he told be I could lower the panels so just the breakers feeding the general circuits were below 48" and the rest serving dedicated circuits above 48". Or he said that a signed paper by the occupant stating that if a breaker trips, that they would call an electrician to reset the breaker, he would let the panel remain where it is.

 

[sparkyrick]

You said residential, is this housing for handicapped people?

Commercial dental clinic. Using "resi panels" because of the 3.5" walls, flush mounted.

 

[infinity]

We don't use the federal ADA so I'm not well versed in it but my gut reaction is still that the inspector is wrong.

 

[sparkyrick]

This was his goto quote from Wisconsin Code:

Comm 16.08 Construction and operation. (1) GENERAL. All electrical power and communication equipment and
lines shall be constructed, installed, operated and maintained so
as to minimize hazards to life and property. All electrical installations shall conform to the National Electrical Code, incorporated
by reference in this chapter, and the requirements specified in this
chapter.
Note: The federal and state Fair Housing Acts, the federal Americans with Disabilities Act and the Wisconsin Commercial Building Code (chs. Comm 61 to 65)
contain requirements relating to making buildings accessible to and usable by people
with disabilities. Some of those requirements apply to the installation of various electrical devices. For example, in the federal fair housing accessibility guidelines,
devices such as light switches, electrical outlets, thermostats and other environmental
controls would meet the requirements if operable parts of the controls are located no
higher than 48 inches, and no lower than 15 inches, above the floor. If the reach is over
an obstruction between 20 and 25 inches in depth, the maximum height is reduced
to 44 inches for forward approach; or 46 inches for side approach, provided the
obstruction is no more than 24 inches in depth. Complete copies of the federal Fair
Housing Accessibility Guidelines or the federal Americans with Disabilities Act
Accessibility Guidelines can be obtained from the Superintend

 

[infinity]

This was his goto quote from Wisconsin Code:

Comm 16.08 Construction and operation. (1) GENERAL. All electrical power and communication equipment and
lines shall be constructed, installed, operated and maintained so
as to minimize hazards to life and property. All electrical installations shall conform to the National Electrical Code, incorporated
by reference in this chapter, and the requirements specified in this
chapter.
Note: The federal and state Fair Housing Acts, the federal Americans with Disabilities Act and the Wisconsin Commercial Building Code (chs. Comm 61 to 65)
contain requirements relating to making buildings accessible to and usable by people
with disabilities. Some of those requirements apply to the installation of various electrical devices. For example, in the federal fair housing accessibility guidelines,
devices such as light switches, electrical outlets, thermostats and other environmental
controls would meet the requirements if operable parts of the controls are located no
higher than 48 inches, and no lower than 15 inches, above the floor. If the reach is over
an obstruction between 20 and 25 inches in depth, the maximum height is reduced
to 44 inches for forward approach; or 46 inches for side approach, provided the
obstruction is no more than 24 inches in depth. Complete copies of the federal Fair
Housing Accessibility Guidelines or the federal Americans with Disabilities Act
Accessibility Guidelines can be obtained from the Superintend

I don't see electrical panels and circuit breakers on the list. If the panel has circuit breakers used also for switching, meaning to daily turn on and off lighting fixtures then he would have a good argument. The average disabled worker does not need to touch circuit breakers.

 

[sparkyrick]

I don't see electrical panels and circuit breakers on the list.

He's calling a circuit breaker an electrical device, which technically it is. What next? Luminaries that need to be at 48" so a wheelchair bound person can change the lamps when they fail???

 

[kwired]

When dealing with large services and distribution it is very common to see equipment that would have operating parts higher than stated, yet no more than the NEC required 2 meters or 6'-7".

It is hard enough to keep employees following OSHA standards in places where employees frequently need to climb ladders or stairs, access things via catwalks, crawl spaces, etc., now these same areas need to be totally ADA compliant?:jawdrop:

 

[sparkyrick]

...now these same areas need to be totally ADA compliant?:jawdrop:

If everything was required to be ADA, the world as we know it would be vastly different.

 

[Strathead]

Is the facility one which is covered by ADA?
If so, see this link.
There you will find:

and

308 basically says 48" max if there are no obstructions keeping a wheelchair from pulling up next to the wall. Lower if there are obstructions.
I think that there is ample support for the inspectors position, with room for dispute about whether the panel is an accessible element in an accessible room and whether it meets the exception to 205.1. But that is limited in turn by:

This definitely shows that circuit breakers are operable parts, but may not totally remove the opportunity to apply the Exception.

No, I have not seen this enforced, but there are a lot of things I have not seen. And if you want to dispute the inspector's finding you will need more than a quick reading of the standard to support you.

PS: The 48" would be to the highest control which is required to be accessible. That will probably include the Main. But not to the top of the panel or even the panel door.

I would appeal to the AHJ, unless the circuit breakers are being used as the switching means for the lights. IMO, the exception you quoted for 205.1 is directly intended to exclude items such as circuit breakers. A tripped breaker is a maintenance/service issue, not an operations issue.

 

[GoldDigger]

Here in NJ (we have a separate State written ADA code) the requirement would only apply if during the normal course of business someone who is handicapped would need to operate that circuit breaker. I would still think that even under the federal ADA the inspector is wrong otherwise a panel would need to be mounted on the floor and what if exceeded 48"?

Actually, if the breakers have to be below 48" and above 14", then that puts a limit on the size of the panel OR requires you to install it sideways. (Provided the main does not end up oriented wrong when you do that.)

 

[kwired]

Actually, if the breakers have to be below 48" and above 14", then that puts a limit on the size of the panel OR requires you to install it sideways. (Provided the main does not end up oriented wrong when you do that.)

I have an upcoming project that will have an I-Line panel in a cabinet 84" tall, also a NQ panelboard in a cabinet 74" tall, and another I-Line panel in a cabinet that is 86" tall. All of these are likely to be mounted very close to the floor or highest handle will be encroaching the 6'-7" max allowed by NEC> If ADA were to apply to these panels we are in big trouble, as getting someone in a wheel chair to the panel locations is likely a problem with ADA. One of them will be in a basement and there is no chair lift or elevator to even allow access, and one of them will likely be pushing the 36" space required by 110.26 about as far as it can, but is likely not enough for ADA either. The third one (the NQ panel) will be easy for someone in a wheel chair to approach, but will have a 400 amp main breaker bottom feed, and will have 72 spaces in the panel, no way the top breakers will be below 48" even if this panel were sitting right on the floor.

 

[sparkyrick]

Ahhhh, the stupidity continues. The inspector made an unexpected visit today and said the Square D panels I installed won't fly because the outside service equipment is Cutler Hammer because of series rating using different manufactures. Ugggh, I give up! The series rating was not marked on the service, per code, either. Plus he said it with a smile on his face, grrrrrrrr. Did I mention the feeders are pulled and terminated and both panels have all branch circuit conduits installed already? We did two Walmarts here and had nothing but problems with this guy. During the last Walmart, we had the plumber have a friendly chat with our inspector and he told him his mission was to make electrician's in the field as miserable he can, like he was treated when he was working in the field. Great, guess, I'm his his next victim

 

[kwired]

Ahhhh, the stupidity continues. The inspector made an unexpected visit today and said the Square D panels I installed won't fly because the outside service equipment is Cutler Hammer because of series rating using different manufactures. Ugggh, I give up! The series rating was not marked on the service, per code, either. Plus he said it with a smile on his face, grrrrrrrr. Did I mention the feeders are pulled and terminated and both panels have all branch circuit conduits installed already? We did two Walmarts here and had nothing but problems with this guy. During the last Walmart, we had the plumber have a friendly chat with our inspector and he told him his mission was to make electrician's in the field as miserable he can, like he was treated when he was working in the field. Great, guess, I'm his his next victim

Series rating will not matter if the available fault current doesn't exceed the SCCR of the breaker in question. If you can prove that rating is not exceeded you can play his game too. If it has been exceeded then I guess maybe the only real issue here may be his method of dealing with problems he does find.

If this guy really wants to keep his job for very long he has the wrong attitude. He may be the AHJ representative but he still serves the people he is inspecting for and not all of them are as stupid as he may think. Abuse of his "power" is one way to lose his job pretty quick.

 

[hurk27]

Ahhhh, the stupidity continues. The inspector made an unexpected visit today and said the Square D panels I installed won't fly because the outside service equipment is Cutler Hammer because of series rating using different manufactures. Ugggh, I give up! The series rating was not marked on the service, per code, either. Plus he said it with a smile on his face, grrrrrrrr. Did I mention the feeders are pulled and terminated and both panels have all branch circuit conduits installed already? We did two Walmarts here and had nothing but problems with this guy. During the last Walmart, we had the plumber have a friendly chat with our inspector and he told him his mission was to make electrician's in the field as miserable he can, like he was treated when he was working in the field. Great, guess, I'm his his next victim

If you were in Indiana I could help you shut this inspector down in a heartbeat, but not sure where this is.

 

[jumper]

Actually, if the breakers have to be below 48" and above 14", then that puts a limit on the size of the panel OR requires you to install it sideways. (Provided the main does not end up oriented wrong when you do that.)

Even if the main was oriented correctly, you would only get to use the lower bus bar for breakers.

240.81 Indicating. Circuit breakers shall clearly indicate
whether they are in the open ?off? or closed ?on? position.
Where circuit breaker handles are operated vertically
rather than rotationally or horizontally, the ?up? position of
the handle shall be the ?on? position.