Code Requirements for food vendor

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jumpshort

Member
What are the code requirements for food vendors that work out of an enclosed trailer? (16' X 8') We have a vendor that has the electrical panel located right above the wash sink. It is powered by a 3kW portable generator for lights and receptacles. Does the working space requirements in 110.26 still apply even though they will never work on the panel energized? I see an awful lot of these food trailers around and I wonder how they get by with the inspections.
 

iwire

Moderator
Staff member
Location
Massachusetts
What are the code requirements for food vendors that work out of an enclosed trailer? (16' X 8') We have a vendor that has the electrical panel located right above the wash sink. It is powered by a 3kW portable generator for lights and receptacles. Does the working space requirements in 110.26 still apply even though they will never work on the panel energized? I see an awful lot of these food trailers around and I wonder how they get by with the inspections.

I do not believe the NEC covers food concession trailers at all.

The other issue that could come up if the NEC did apply is how would inspection be handled?

For what it is worth I have never seen the NEC clearance requirements met in these types of trailers.
 

acrwc10

Master Code Professional
Location
CA
Occupation
Building inspector
The only 3 departments that I can think of that have authority over them are Dept of transportation (or the DMV) the health dept and city business licensing.
 

jumpshort

Member
I do not believe the NEC covers food concession trailers at all.

The other issue that could come up if the NEC did apply is how would inspection be handled?

For what it is worth I have never seen the NEC clearance requirements met in these types of trailers.

I can't see where it's "not" covered under 90.2(B) It should be. They have a license for the trailer from the health department. I would think that they wouldn't just look at the sanitary/hygiene issues but also potential issues that could arise from faulty wiring in the trailer itself. I'm guessing that because it is in all likelihood that the trailer will be powered from a GFCI source either from a portable generator or an outside receptacle that should be GFI protected, then there is no hazard?
 

K8MHZ

Senior Member
Location
Michigan. It's a beautiful peninsula, I've looked
Occupation
Electrician
I can't see where it's "not" covered under 90.2(B) It should be. They have a license for the trailer from the health department. I would think that they wouldn't just look at the sanitary/hygiene issues but also potential issues that could arise from faulty wiring in the trailer itself. I'm guessing that because it is in all likelihood that the trailer will be powered from a GFCI source either from a portable generator or an outside receptacle that should be GFI protected, then there is no hazard?

It's not covered under 90.2(A), that's why.

Remember, a premises is land or real estate and the buildings and structures built on said land or real estate. Trailers aren't premises', and that's why mobile homes and RV's are specifically mentioned.
 

GoldDigger

Moderator
Staff member
Location
Placerville, CA, USA
Occupation
Retired PV System Designer
It's not covered under 90.2(A), that's why.

Remember, a premises is land or real estate and the buildings and structures built on said land or real estate. Trailers aren't premises', and that's why mobile homes and RV's are specifically mentioned.
And that is why there are rules for food trucks/food carts, just not in the NEC. (Anybody know offhand what does apply to the electrical elements?)
 

K8MHZ

Senior Member
Location
Michigan. It's a beautiful peninsula, I've looked
Occupation
Electrician

K8MHZ

Senior Member
Location
Michigan. It's a beautiful peninsula, I've looked
Occupation
Electrician
Also remember that OSHA only applies to employees, not owners.

I don't find it odd at all that these trailers are not covered under any electrical code. Farms (Article 547) are exempt from electrical codes in Michigan. No permits, inspections or licenses needed and there is no requirement to follow any code.
 

iwire

Moderator
Staff member
Location
Massachusetts
Also remember that OSHA only applies to employees, not owners.

That is a darn good point and it is likely that there will be employees working in the trailer.

That being said OSHA has a lot of electrical requirements that are taken directly from past NEC editions.
 

iwire

Moderator
Staff member
Location
Massachusetts
Farms (Article 547) are exempt from electrical codes in Michigan. No permits, inspections or licenses needed and there is no requirement to follow any code.

That is just plain nuts.

But on the other hand even if there were enforcement would be an issue.
 

K8MHZ

Senior Member
Location
Michigan. It's a beautiful peninsula, I've looked
Occupation
Electrician
That is just plain nuts.

But on the other hand even if there were enforcement would be an issue.

We just had a code upgrade class. The instructor snidely remarked that the farmers must have a good lobby in Michigan.

We also exempt the parts in Chapter 5 that do not allow the metal in LFMC to be used as a ground.

And, we also exempt 2011 110.24 so we don't have to worry about stuff like this:

http://forums.mikeholt.com/showthread.php?t=134106

Back to 547 some interesting discussions came up as to what was an agricultural building. MJ was legalized for med use in Michigan a couple years ago. I'll leave it at that.

So back to our scheduled program, already in progress. :p
 

iwire

Moderator
Staff member
Location
Massachusetts
I can't see where it's "not" covered under 90.2(B) It should be.



Lets say it s covered by the NEC.

Lets say you build the trailer in Mayberry, you pull a permit, you rough it, you get a rough inspection, you do the finish and get a final inspection signed off by the Mayberry wiring inspector.

Now the food vendor drags the trailer over to Hooterville for the annual pig racing competition and Mr Hanny, the Hooterville part time wiring inspector wants to know if the trailer complies with the NEC.

You say: 'Sure, it was inspected in Mayberry'

To which Mr Hanny replies: 'This is not Mayberry, it must be inspected here in Hooterville. And if you are going to take it to the Mount Pilot tobacco festival next month it will need to be inspected there as well.

You see the issue?

As K8MHZ pointed out and I agree .... a trailer is not a premises.
 

qcroanoke

Sometimes I don't know if I'm the boxer or the bag
Location
Roanoke, VA.
Occupation
Sorta retired........
Lets say it s covered by the NEC.

Lets say you build the trailer in Mayberry, you pull a permit, you rough it, you get a rough inspection, you do the finish and get a final inspection signed off by the Mayberry wiring inspector.

Now the food vendor drags the trailer over to Hooterville for the annual pig racing competition and Mr Hanny, the Hooterville part time wiring inspector wants to know if the trailer complies with the NEC.

You say: 'Sure, it was inspected in Mayberry'

To which Mr Hanny replies: 'This is not Mayberry, it must be inspected here in Hooterville. And if you are going to take it to the Mount Pilot tobacco festival next month it will need to be inspected there as well.

You see the issue?


As K8MHZ pointed out and I agree .... a trailer is not a premises.

Understood and a good point.
But if you can call a 4x4 post with a disconnect on it a structure, I don't see why you couldn't call a trailer a premise....... ;)
 

K8MHZ

Senior Member
Location
Michigan. It's a beautiful peninsula, I've looked
Occupation
Electrician
Understood and a good point.
But if you can call a 4x4 post with a disconnect on it a structure, I don't see why you couldn't call a trailer a premise....... ;)

Because 'structure' is defined that way in Article 100. There is no NEC definition of premises, so we just use the one in the dictionary.

From Reference.com

premises. a. a tract of land including its buildings.

b. a building together with its grounds or other appurtenances.


c. the property forming the subject of a conveyance or bequest.

Remember, the NEC not only can make up definitions of words, they can make up the words, too. Like ampacity.
 

jumpshort

Member
I think if you pose the question over in one of the automotive engineering forums you'll get better answers than you're getting on here.

These are all good points (most of them anyway). I'm going to chock this one up with the statement: "Tell me where it says in the code that you don't have to do that." Where my reply has always been "Tell me where it says I do"
 
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