2008 proposal 110.26

[ryan_618]

I plan on submitting quite a few changes for the 08 cycle, and would like whatever help you guys can give. Thanks in advance.


110.26(A)

Working space. Working space for equipment operating at 600 volts, nominal, or less to ground and likely to require examination, adjustment, servicing, or maintenance while energized shall comply with the dimensions of 110.26 (A)(1), (2), and (3) or as required or permitted elsewhere in this code.

Change to read:

Working space. Working space for the following equipment, operating at 600 volts, nominal, or less to ground and likely to be examined, adjusted, serviced, or maintained while energized shall comply with the dimensions of 110.26 (A)(1), (2), and (3) or as required or permitted elsewhere in this code.
(1) Switchboards
(2) Panelboards
(3) Industrial control panels
(4) Meter socket enclosures
(5) Motor control centers
(6) Transformers
(7) Switches, where used as a disconnecting means.


Substantiation: As written, this crucial safety provision is unenforceable. The phrase ??likely to require?? when taken literally, would mean to ?command or insist on? working on energized equipment (see ?require? in the American Century Dictionary). This would be in direct opposition to the standards put forth by OSHA and the NFPA 70E. In fact, the installation of a remote means of disconnect could be used to argue that the equipment need not be worked on while energized. It is obvious that this is not the true intent of the code.

Items 1-7 exist in 110.16, and are therefore obviously intended to have the working space required by 110.26. Items 6 and 7 are very frequently examined, adjusted, serviced and maintained while energized. The list format is crucial to the proper application of this section. The present code text now requires that all equipment that might, in the eyes of the authority having jurisdiction, be worked on while energized. Due to the definition of ?equipment?, this would include every box, every luminaire, every general purpose snap switch, every receptacle, and anything else that meets the definition. This also is obviously not the intent of the code.

Section 110.26(A) is crucial for maintaining the safety of our electrical workers and inspectors and therefore must be written in clear, concise and enforceable language.

 

[bphgravity]

Re: 2008 proposal 110.26

I feel the words "while energized" should also be removed from the text. That way, the terms "likely to be..." could also be removed.

New Text:


Working space for the following equipment, operating at 600 volts, nominal, or less to ground shall comply with the....

I feel this way, any and all loop holes for enforcement will be removed. Working space is needed for equipment regardless if it is energized or not, and for whatever reason you need that working space for.

 

[petersonra]

Re: 2008 proposal 110.26

Originally posted by bphgravity:
I feel the words "while energized" should also be removed from the text. That way, the terms "likely to be..." could also be removed.

New Text:


Working space for the following equipment, operating at 600 volts, nominal, or less to ground shall comply with the....

I feel this way, any and all loop holes for enforcement will be removed. Working space is needed for equipment regardless if it is energized or not, and for whatever reason you need that working space for.

AMEN!

 

[hurk27]

Re: 2008 proposal 110.26

I agree with the intent, but I do see so problems with saying all disconnects need to comply with this.
There will be some areas that it would be imposable to install a switch disconnect to remove power to equipment IE... crawl spaces, attics, and some equipment room's. To use the argument that this should apply when checking for voltage should not be, as we all check for voltage at every receptacle or switch, and we have to do it live. Also the fact that there is some disconnects on the market that provide full protection from shock by covering all energized parts in them and are listed for use with out a dead front. These type of disconnects are a pullout type that the blades of the pullout are de-energized before the the blades are exposed, and the contacts are well behind a plastic barrier that prevent contact by anyone. If they are listed for use without a dead front then UL considers them as being safe when the door of it is opened. as any child playing outside can open them but since there is no exposed energized parts there is no safety hazard. I would accept an exception to the change you propose that says:

Exception 1. where the disconnect is listed for use without a dead front cover and there is no exposed energized electrical parts, or fuses, this section shall not apply.

Exception 2. Where a single pole or a double pole or a three-way or a four-way type switch is used to control lighting outlets, switched receptacle, or a appliance, that is used to control equipment in normal use of the equipment, this section shall not apply.

I posted awhile back about and even left a link to a web site that one could see what I was talking about.

[ September 29, 2004, 12:23 AM: Message edited by: hurk27 ]

 

[charlie]

Re: 2008 proposal 110.26

Has this caused any kind of problem? What has happened because of the existing wording? If it is working well as it is, why fix it? Answer these questions in your substantiation or it will be shot down.

 

[don_resqcapt19]

Re: 2008 proposal 110.26

Charlie,

Has this caused any kind of problem? What has happened because of the existing wording? If it is working well as it is, why fix it? Answer these questions in your substantiation or it will be shot down.

The easiest way for Ryan and the other inspectors to show a problem, is to start "red-tagging" all of the kithen counter top receptacles as a violation of 110.26, because under the current code wording, they are.
Don

 

[steve66]

Re: 2008 proposal 110.26

I'll be the devils advocate here: I like the loopholes. I think some transformers and switches never need to be worked on while hot. So why waste valuable building space when it's not necessary.

The current wording lets someone decide what devices are likely to need working space (engineer, electrician, or AHJ) I think most of these people can make reasonable judgements, and I think most would error on the side of safety.

Just my opinion:
Steve

 

[ryan_618]

Re: 2008 proposal 110.26

I think the items that should require the space need to be spelled out. Look at 110.16 and see how similiar the langauge is. You have the same phrase "likely to require...", but you also have the items that the rule applies to spelled out for you. If that weren't the case, I can assure you there would be no two inspectors in the world that would be consistent with each other on which equipment the sticker is required to be on. I am not trying to change any intent, just trying to make a very poorly written provision enforcable. If you have access to the style manual, read the list of uneforcable and vague terms, and notice that the existing text has them.

 

[sandsnow]

Re: 2008 proposal 110.26

Ryan
How about adding "including but not limited to the following" or have an item #8 for "other equipment as required"

I can think of one thing you did not cover and that would be single circuit breaker enclosures such as mounted on a genset

There probably is more and I would not like to see our hands tied here

 

[eprice]

Re: 2008 proposal 110.26

As an example of the need for this change, just look at the difference in opinion we have seen as to the requirement of working space in front of a non-fused A/C disconnect. I also agree with Don's comment about kitchen counter top receptacles. As an inspector, I see this section as being so vague as to be almost unenforceable. The latitude of possible intrepretation of this section is so broad, that I can only go with the "accepted norm" in my area. That much gray area prevents any kind of uniformity from one area to another.

Wayne addressed one of my concerns about the proposed change with his exception #2. Without that, I think the definition of a "disconnecting means" is broad enough that "(7) Switches, where used as a disconnecting means." would include most if not all wall switches.

Larry, I understand the feeling of not wanting our hands tied, but I see it this way: If there's something else that comes to mind, lets add it to the list. If nothing comes to mind, then whatever it is, maybe it happens so seldom or is a small enough problem that we can wait for the next code cycle to add it. Adding "(8) other equipment as required" would defeat the purpose of the change, and put us back where we are now IMO.

 

[charlie b]

Re: 2008 proposal 110.26

Originally posted by ryan_618: Substantiation: . . . . The phrase ??likely to require?? when taken literally, would mean to ?command or insist on? working on energized equipment (see ?require? in the American Century Dictionary).

While I agree that there is a need for a clarification of this NEC Article, I think you pulled the wrong definition out of the list of definitions that apply to the word ?require.? The NEC Article does not use the word ?require? in the context of one person issuing a command to another. Rather, the context is that of ?need.? The dictionary definition that I would apply is, ?Have a compelling need for.? Does the equipment ?have a compelling need for? maintenance? If so, does the equipment ?have a compelling need for? maintenance while it is energized?

The problem I have with this wording is that the notion of ?need? is purely subjective. You say it needs? Well I say it doesn?t need. More to the point, the designer can say that it doesn?t need (i.e., the designer says that the electrician can turn it off before working on it), but later the owner refuses to allow the equipment to be turned off for maintenance. That is the reason the article is not enforceable.

The problem I have with your suggested wording is that the list is not complete, nor could it ever be complete. I don?t want the Inspector to be put in the position of having to approve an installation of, for example, a VFD or a UPS or an ATS (which is a switch, but one that is not used as a disconnecting means), when there is inadequate working space, for the simple reason that that item of equipment is not on the list.

What?s my solution? To start back with the basics. What is the reason for having working clearance? It is to ensure the worker has room to fall. It is to permit the electrical current flowing through the person?s body to cause the body to collapse, so that the weight of the falling body will pull the hands away from the energized equipment. It is there because the current flowing through the hands can force the hands to hold onto the circuit, preventing the person from voluntarily letting go. It is to give the worker a chance, however slight, to survive the experience.

I would suggest adopting Bryan?s text, and then adding the following:

Exception: Where the conditions of maintenance and supervision ensure that the equipment cannot be examined, adjusted, serviced, or maintained while energized, and where administrative controls are in place to prohibit performance of these activities while the equipment is energized.

p.s. Thanks, Ryan, for bringing this issue to light.

 

[rbalex]

Re: 2008 proposal 110.26

I hate subjective Code, so I like eliminating ?likely to require.? I don?t like attempts at comprehensive lists though because it creates the problem Charlie B brought up with overlooking a class of equipment. This implies that class is exempt when it shouldn?t be which then immediately suggests the solution of either ?but not limited to? or ?other equipment as required? which becomes subjective again.

I would prefer something like:

110.26 (A) Working Space . Working space for equipment operating at 600 volts, nominal, or less to ground and that requires examination, adjustment, servicing, operation or maintenance of exposed live parts shall comply with the dimensions of 110.26(A)(1), (2), and (3) or as required or permitted elsewhere in this Code. Where work is for the operation or inspection of dead-front equipment only or access is required to work on de-energized equipment, a minimum horizontal depth in the direction of the work of 762 mm (30 in.) shall be provided.

This type wording works as long as an inspector avoids attempting to use a ?crystal ball? about what someone may do in the future. For commercial / industrial work this is a design and safety related work practices issue, not an inherent installation safety issue and its something for 70E to deal with. In this case, the equipment would be permitted to operate, but "live work" on it would be prohibited without meeting the 110.26(A)(1), (2), or (3)requirements. An absolute minimum in all cases is specified. For residential / consumer applications and some industrial cases, it may be appropriate to clarify that countertops may be permitted in the workspace for receptacle outlets.

[ September 29, 2004, 04:23 PM: Message edited by: rbalex ]

 

[charlie b]

Re: 2008 proposal 110.26

Good idea, Bob. I especially like the idea of requiring a minimum working space, even if the equipment is turned off. I would like the architects of the world to be compelled to leave room for the maintenance worker to work safely.