Article 110.26(B) Clear Spaces Clarification

[theseeker2]

NEC 2014 Article 110.26(B) Clear Spaces. Working space required by this section shall not be used for storage. When normally enclosed live parts are exposed for inspection or servicing, the working space, if in a passageway or general open space, shall be suitably guarded.

Mike Holt?s Illustrated Guide to Essential Rules of the National Electrical Code, Based on the 2011 NEC
INTRODUCTION TO ARTICLE 110?REQUIREMENTS FOR ELECTRICAL INSTALLATIONS
Page 18 reads:
(B) Clear Working Space. The working space required by this section must be clear at all times. Therefore, this space isn?t permit*ted for storage. When normally enclosed live parts are exposed for inspection or servicing, the working space, if in a passageway or gen*eral open space, must be suitably guarded.

I am seeking guidance on the acceptability of temporarily placing a rolling cart within the defined working space of an electrical enclosure (see picture attached). For frame of reference, the electrical enclosure is mounted to the left of the cart and the work space is defined by 5S tape on the floor. The cart would only be rolled to this position intermittently during working hours as needed. When the cart is present an associate standing on the gray mat would be removing objects from the cart and then the cart would be removed (returned to its storage area). When this area is not in use (i.e. after hours, if the work area is unmanned, or if the work area is shut down for maintenance) there would be no cart in this position (i.e. the cart is not stored here). Based on the language in the NEC this appears to be acceptable as the space is not used for storage but based on guidance provided in "Introduction to Article 110" this space is to be clear at all times so this would not be allowed. The application is in Florida so I have a particular interest in how a Florida AHJ would interpret this requirement but would like to understand what is normally accepted. I don't want to approve a workspace layout that could result in a violation but I also don't want to constrain the workspace layout and force a layout redesign if this is acceptable.

 

[charlie b]

With all due respect to Mike and to the people who help him write his books, it must be said that his books are intended for training purposes, and only the words in the code itself are enforceable. In my designs, I tend to be protective (perhaps overly so) of the working space. However, in this instance, I would agree that the planned use of this space would not create a code violation, nor would it create a dangerous situation for a potential future worker. I agree that what you described does not constitute ?storage.? And I reiterate that the words in Mikes book, specifically ?must be clear at all times,? do not govern the situation.

My only reservation comes from the tendency of owners to change their intended use of space without taking any rule book into consideration. What, for example, would stop the owner from using the cart's present storage location for something else, and then storing the cart in front of the panel thereafter?

 

[MasterTheNEC]

I would have to echo what Charlie has already stated. This cart is on wheels, it is not intended to remain in this location for long periods of time and in my opinion it is not creating a "storage space" that would violate Section 110.26(B). If someone says "well it could remain there for long periods of time" my response as an inspector is, I am not an "expector" as I am an "Inspector" and this does not look like it is being used (at the time of my inspection) as a storage space.

Just my thoughts on it.

 

[don_resqcapt19]

While I don't see a real safety issue, I think it is a code violation. If the cart is not being used, it is being "stored" and the area where the cart has been placed becomes a "storage area".

 

[GoldDigger]

While I don't see a real safety issue, I think it is a code violation. If the cart is not being used, it is being "stored" and the area where the cart has been placed becomes a "storage area".

But if the cart is being used as a dispensing platform for parts and materials, with someone there working in front of it, I would have to say that it is not being stored. The function of a cart goes beyond just moving things.

If the guy leaves it there at the end of his shift, you have a problem. If he leaves it there over lunch break, it becomes a judgement call, IMHO.

 

[starbolin]

.... I don't want to approve a workspace layout that could result in a violation but I also don't want to constrain the workspace layout and force a layout redesign if this is acceptable.

Even were you to rationalize that this is not an NEC violation it is still a work place safety violation and a fire safety violation. In no jurisdiction that I have worked in ( an, admittedly, small sample ) would you be allowed to park work carts in a code required clearance area.

 

[augie47]

Most electrical inspectors that I know would move the cart or asked it to be moved
if they were inspecting. Beyond that, my opinion, from what you state, is that the cart is being used as a "work station" albeit intermittently, and that would open up a world of liabilities were there be an incident. All safety inspectors I know would required the area required by Code and marked by your tape to be clear at all times.
It's a fine line, but were I on a jury I would see a distinct difference from a work cart that had accidently been allowed within the zone and one that was purposely stationed there to allow completion of a task.

 

[MasterTheNEC]

While I don't see a real safety issue, I think it is a code violation. If the cart is not being used, it is being "stored" and the area where the cart has been placed becomes a "storage area".

At what point do you cross the line from being an Inspector to an Expector? The floor is taped off, the intent of the areas use is expressed so we have to assume this is the intended use for that space. It is not being intended for storage...it is being used as a space for the immediate need and then when functions sense it is being placed back into compliance until the next time it needs to have a temporary non-storage use.

Sometimes I think we can get way to "BLACK and WHITE" on a rule and not consider a common sense approach to each unique application. Just my thoughts on it, please do not ban me:angel:

 

[102 Inspector]

As an inspector, there is no "common sense" in government. As a firefighter, my concern would be for the immediate action required to access a possible disconnecting means being obstructed by a portable cart. that said, this situation can happen at anytime and any location. the wealth of knowledge and experience that is expressed on this site clearly indicates that not everyone will agree all the time, and some of us will never agree with situations like this. the AHJ needs to make the call and stand by it, right or wrong. And yes, after 25 years inspecting, I try to still apply some common sense toward my inspections and include my opinion from time to time. My opinion is not enforceable under the provisions of the code though.

 

[charlie b]

As a firefighter, my concern would be for the immediate action required to access a possible disconnecting means being obstructed by a portable cart.

If you really are a firefighter, then I honor you for that service. However, having said that, I will add that a firefighter's ability to access a breaker inside a branch circuit panel is not related in any way to the prohibition against storing anything within the working clearance. The 110.26 rules begin with the notion of equipment that is likely to require work while energized. It does not say anything about equipment that is likely to require access to turn something off during an emergency.

 

[102 Inspector]

28 years with a volunteer department, Assistant Chief for past 8 years and 25 years as code official. My point as a firefighter was not a code violation issue, but some observation on how some areas have "hidden" the panel and thus making it difficult for firefighters to find it when necessary. Remember, firefighters are not the brightest crayon in the box. As a firefighter, I would encourage them to find an alternate location and as a code official I would review the situation in front of me and try to make the best decision I could at that time. I respect all the conversation on this forum and get really upset when I hear other inspectors state "I would like to see this". It does not matter what I would like to see, it is my interpretation of the text in the code that is enforceable. A judge does not really care what my opinion is, just what the code book says. And thanks for the acknowledgement, it truly is an exciting part of my life.

 

[pfalcon]

Scheduled use is not temporary. Scheduled use is permanent regardless of duration.

By the OP description it's a permanent storage and therefore a prohibited use.
The duration is not long but it's regularly scheduled.

My 2 cents.

 

[iwire]

While I don't see a real safety issue, I think it is a code violation. If the cart is not being used, it is being "stored" and the area where the cart has been placed becomes a "storage area".

I agree with this 100% and I am very sure OSHA inspectors would have no delay in assigning a fine for doing this.

 

[jxofaltrds]

I see no code violation.

110.1 Scope. This article covers general requirements for the
examination and approval, installation and use, access to and
spaces about electrical conductors and equipment; enclosures
intended for personnel entry; and tunnel installations.

110.26 Spaces About Electrical Equipment. Access and
working space shall be provided and maintained about all
electrical equipment to permit ready and safe operation and
maintenance of such equipment.



Where is ?must be clear at all times,?????

What if I need scaffolding to work on the ceiling?

What about a mop bucket?

EDIT:

90.1 Purpose.
(A) Practical Safeguarding. The purpose of this Code is
the practical safeguarding of persons and property from
hazards arising from the use of electricity.

 

[iwire]

I see no code violation.

110.1 Scope. This article covers general requirements for the
examination and approval, installation and use, access to and
spaces about electrical conductors and equipment; enclosures
intended for personnel entry; and tunnel installations.

110.26 Spaces About Electrical Equipment. Access and
working space shall be provided and maintained about all
electrical equipment to permit ready and safe operation and
maintenance of such equipment.



Where is ?must be clear at all times,?????

What if I need scaffolding to work on the ceiling?

What about a mop bucket?

EDIT:

90.1 Purpose.
(A) Practical Safeguarding. The purpose of this Code is
the practical safeguarding of persons and property from
hazards arising from the use of electricity.

Mike, no one has said it must be clear at all times.

Regardless of the code sections you posted the code section we are talking about says 'shall not be used for storage'.

(B) Clear Spaces. Working space required by this section
shall not be used for storage. When normally enclosed live
parts are exposed for inspection or servicing, the working
space, if in a passageway or general open space, shall be
suitably guarded.

They cannot plan to store a cart in that space.

 

[jxofaltrds]

Mike, no one has said it must be clear at all times.

Regardless of the code sections you posted the code section we are talking about says 'shall not be used for storage'.




They cannot plan to store a cart in that space.

OP said clear at all times.

Agreed not for storage. While not defined I think most of us know when an area is being used for storage.

 

[GoldDigger]

And this entire debate hinges on whether a cart which is actively being used is "stored" any time that it is not moving.

 

[MasterTheNEC]

A classic example of individuals normally arguing for a less restrictive code yet they wish supporting a rigid strict (uncompromising) interpretation of the code as written. If the cart is simply there to facilitate an activity but is not stored their (as stated in the OP's statement) then it is not being stored there and I do not see the violation.

Again, everyone is entitled to opinions and based on the verbiage of the NEC it warrants your own opinion when being enforced.

 

[iwire]

OP said clear at all times.

I don't see the OP saying that at all.

 

[Little Bill]

Mike Holt?s Illustrated Guide to Essential Rules of the National Electrical Code, Based on the 2011 NEC
INTRODUCTION TO ARTICLE 110?REQUIREMENTS FOR ELECTRICAL INSTALLATIONS
Page 18 reads:
(B) Clear Working Space. The working space required by this section must be clear at all times. Therefore, this space isn?t permit*ted for storage. When normally enclosed live parts are exposed for inspection or servicing, the working space, if in a passageway or gen*eral open space, must be suitably guarded.

I am seeking guidance on the acceptability of temporarily placing a rolling cart within the defined working space of an electrical enclosure (see picture attached). For frame of reference, the electrical enclosure is mounted to the left of the cart and the work space is defined by 5S tape on the floor. The cart would only be rolled to this position intermittently during working hours as needed. When the cart is present an associate standing on the gray mat would be removing objects from the cart and then the cart would be removed (returned to its storage area). When this area is not in use (i.e. after hours, if the work area is unmanned, or if the work area is shut down for maintenance) there would be no cart in this position (i.e. the cart is not stored here). Based on the language in the NEC this appears to be acceptable as the space is not used for storage but based on guidance provided in "Introduction to Article 110" this space is to be clear at all times so this would not be allowed. The application is in Florida so I have a particular interest in how a Florida AHJ would interpret this requirement but would like to understand what is normally accepted. I don't want to approve a workspace layout that could result in a violation but I also don't want to constrain the workspace layout and force a layout redesign if this is acceptable.

I don't see the OP saying that at all.

Put on your glasses!
Although he was quoting Mike Holt, he still said it in the OP!