Code compliant LOTO devices

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iwire

Moderator
Staff member
Location
Massachusetts
There is a choice, the breaker lock is an option. It's an exception to make things easier for us.

You can forget the breaker lock if you put a disconnecting means at the appliance.

And that might not be used either but we still install them.
 

goldstar

Senior Member
Location
New Jersey
Occupation
Electrical Contractor
From what I remember the DW was 2 cabinet spaces over from the sink cabinet. So that wasn't an option for us. But, I do that all the time when I can just to avoid this mess. Thanks.


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iwire

Moderator
Staff member
Location
Massachusetts
A single pole switch on the back splash was a common method here, or in the cabinet under the sink beside the DW.

I think that has been forgotten in place of using a cord and plug connected DW now.
 

goldstar

Senior Member
Location
New Jersey
Occupation
Electrical Contractor
Just thinking in advance, since a DW will now have to be GFCI protected under the 2014 NEC (if I Remember correctly) if I have the same situation where I have to wire it direct can I use a faceless GFCI at the counter top as the disconnect means ? If not, can I use a switch over faceless GFCI instead ?
 

kwired

Electron manager
Location
NE Nebraska
Just thinking in advance, since a DW will now have to be GFCI protected under the 2014 NEC (if I Remember correctly) if I have the same situation where I have to wire it direct can I use a faceless GFCI at the counter top as the disconnect means ? If not, can I use a switch over faceless GFCI instead ?
GFCI's need to be able to be switched off when there is no power to be compliant as a disconnecting means. Most (more like almost all) GFCI's that are not also a circuit breaker need to be powered before you can make them open the circuit. The disconnecting means also needs to indicate whether it is on or off, test and reset buttons sort of do that but also isn't all that clear compared to On and Off indication.
 

goldstar

Senior Member
Location
New Jersey
Occupation
Electrical Contractor
I understand your point but if the GFCI isn't powered neither is the DW. So, in answering the second part of my question a side to side rocker switch wouldn't be acceptable as a disconnect means. However, an off or tripped indicator light on the GFCI would indicate that the device and connected appliance are off. (IMHO)


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kwired

Electron manager
Location
NE Nebraska
I understand your point but if the GFCI isn't powered neither is the DW. So, in answering the second part of my question a side to side rocker switch wouldn't be acceptable as a disconnect means. However, an off or tripped indicator light on the GFCI would indicate that the device and connected appliance are off. (IMHO)


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If the branch circuit is off you can't trip the GFCI. Now say you are working on the dishwasher and someone turns on the branch circuit - see why the GFCI is not an acceptable disconnecting means. A switch can still be opened even if there is no power. This is topic that has come up before and most agree that a GFCI (other then a GFCI breaker) is not an acceptable disconnecting means.
 

iwire

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Staff member
Location
Massachusetts
Too lazy to find it now but the UL white book basically tells us GFCIs can be used as switches if labeled on and off along with test and reset.
 

kwired

Electron manager
Location
NE Nebraska
Too lazy to find it now but the UL white book basically tells us GFCIs can be used as switches if labeled on and off along with test and reset.
And I believe to qualify as a disconnecting means they must also be able to open the circuit even if not powered.
 

kwired

Electron manager
Location
NE Nebraska
404.11 Circuit Breakers as Switches.
A hand-operable circuit breaker equipped with a lever or handle, or a power-operated circuit breaker capable of being opened by hand in the event of a power failure, shall be permitted to serve as a switch if it has the required number of poles.

this section only applies to circuit breakers, but is a similar issue, don't know if I will find anything similar that addresses a GFCI device used as a switch.
 

goldstar

Senior Member
Location
New Jersey
Occupation
Electrical Contractor
Too lazy to find it now but the UL white book basically tells us GFCIs can be used as switches if labeled on and off along with test and reset.
Don't go nuts trying to find it. As far as I know a rocker switch over GFCI is not labeled on/off. However, from what I recollect, with some manufacturers if there is no power to a GFCI receptacle and you press the test button it will open the circuit.
 

kwired

Electron manager
Location
NE Nebraska
Don't go nuts trying to find it. As far as I know a rocker switch over GFCI is not labeled on/off. However, from what I recollect, with some manufacturers if there is no power to a GFCI receptacle and you press the test button it will open the circuit.

I never seen one that does. The test button is a switch in a circuit with a resistor that introduces real current into the monitored circuit which will initiate the trip circuitry. Closing an unenergized test circuit will not cause the main circuit to open.

You need a manual main switch as well as the test button like a GFCI breaker has to get manual operation as well as test function.
 

iwire

Moderator
Staff member
Location
Massachusetts
And I believe to qualify as a disconnecting means they must also be able to open the circuit even if not powered.

I do not know.

Here is the info I recalled

GROUND-FAULT CIRCUIT
INTERRUPTERS (KCXS)
GENERAL

<SNIP>

The ‘‘TEST’’ and ‘‘RESET’’ buttons on the GFCIs are only intended to
check for the proper functioning of the GFCI. They are not intended to be
used as ‘‘ON/OFF’’ controls of motors or other loads unless the buttons
are specifically marked ‘‘ON’’ and ‘‘OFF.’’ Products with ‘‘ON’’ and ‘‘OFF’’
markings have been additionally covered under Motor Controllers,
Mechanically Operated and Solid-state (NMFT).


<SNIP>

I guess we would have to look at the requirements for controllers but a controller is not always a disconnect anyways so it seems like an up hill battle. Just put a cord and plug on it.
 

kwired

Electron manager
Location
NE Nebraska
I do not know.

Here is the info I recalled



I guess we would have to look at the requirements for controllers but a controller is not always a disconnect anyways so it seems like an up hill battle. Just put a cord and plug on it.

I agree just put a cord and plug on it for most instances, but I recall it being mentioned the receptacle wouldn't be in the adjacent cabinet which is also a problem.
 

mrsafetyman

Member
Location
Buffalo NY
i can assist

i can assist

Would someone please point me in the right direction as to what LOTO devices are acceptable for SqD HL breakers ? A colleague of mine failed an inspection twice. Used a Ideal product first time around and was not acceptable to the EI. IMHO it served the purpose by flipping the plastic device around so the breaker can be held in the off position. I believe the EI is looking for something to actually be "lockable" with an actual lock. For you NJ contractors this job is in Verona, NJ if that means anything.

Quote: you need to contest any citation especially if you utilized a breaker LOTO device that is designed, manufactured and sold as such. most can be abated and thrown out if the right device was used. Breaker LOTO devices are sold and utilized in plant environments all the time. Make sure the LOTO device is capable of having a lock and attached. TAGS are another way to performed LOTO or locking the cabinet BUT you must use a sign to advise others why the cabinet is locked!
kdd132_2_1.jpg
1TDB2_AS01
circuit-breaker-lockout-tag-application-kdd460-kdd168.jpg
this satisfies the OSHA LOTO elements of LOTO. Just because you LOTO a single pole breaker off doesn't means the power is off especially on 277 volt lighting systems which utilizes a single neutral for three hots. You turned of a breaker for a single row of 277v lights. the two other rows will share the same neutral of the circuit de-energized The two light circuits not de-energized are feeding power on the shared neutral of the light you de-energized. This means that NEUTRAL HAS 277 VOLTS returning into the system. You must find the lighting circuits sharing that neutral and de-energize all three breakers. Always test the neutral to ground on 277v lighting prior to touching it. Remember an element is the TAG or restraint must be durable. The lock must be durable. Hope this helps https://www.osha.gov/SLTC/controlhazardousenergy/standards.html
 

iwire

Moderator
Staff member
Location
Massachusetts
Quote: you need to contest any citation especially if you utilized a breaker LOTO device that is designed, manufactured and sold as such. most can be abated and thrown out if the right device was used.

The device you have shown will satisfy OSHA, it will not satisfy the NEC requirement under discussion.

For this application the NEC requires the device to remain attached to the breaker regardless of it being in use or not.
 
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