Access to Working Space

[malachi constant]

We have a project being held up for occupancy due to the building inspector objecting to the location of a 100A breaker panel. The panel is located in an M/E room which contains a tall ship's ladder. Imagine the ladder being about 18"~24" off the wall, you squeeze past it so now you are under it. The panel is located under here, on the same wall you squeezed past, tucked a few feet in from the ladder. There is no obstruction above, and there is adequate (more than code-minimum) working clearance in front of it. The door opens just fine. Etc. The electrical inspector was consulted on this prior to installation and had no problem with it. However it is now installed and the building inspector says there is "not adequate access into the room" and would like us to comment.

I oversimplified one thing about the existing space - after you squeeze past the stairs through that 18"~24" opening there is a vertical duct about 8" deep. Requires a taller person to duck a little as they go past it so their head doesn't hit the bottom side of the stairs. That said there are plenty of folks on site who are large and tall and none have issue squeezing back there.

I have personally had to crawl over/under/through some pretty challenging obstacles in my career to get to a panel. I can understand the desire to make panels more accessible, but this does not strike me as particularly onerous. That said if there is a code issue, be it electrical or building code, then code is code and we'll figure out somewhere else to move it. We are operating under 2014 NEC, all I can find is:
* 110.26 "Access and working space shall be provided and maintained about all electrical equipment to permit ready and safe operation and maintenance of such equipment." Equipment is broadly defined and many pieces of "equipment" are only maintainable in a crawl space or on a ladder.
* 110.26 (C) (1) "At least one entrance of sufficient area shall be provided to give access to and egress from working space about electrical equipment." Great. "Sufficient area." I read that as ""sufficient area to give access to and egress from working space..." which (depending on the exact definition of sufficient area" I would argue we have here.
* 110.26 (D) requires adequate illumination, I doubt there is a light under there. That is probably a necessary change to meet NEC.

If any of you have experience here please let me know. Thanks!

 

[REDICO]

The door to the M/E room must have an specific size. You should have the same unobstructed space from the panel all the way to the door.

Imagine trying to get out of that room under that ladder if you we injured.

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[JFletcher]

A picture or two would help greatly in answering your questions.

Perhaps it's not an NEC issue, but a building code, OSHA, or life/safety issue. If egress from the panel obstructed by that ladder, would someone be able to easily get out in case of emergency? Could rescue personnel get to someone at the panel who needs medical attention? I take it there is no access by going around the other side of the ladder?

It may be cheaper to install a folding/attic style ladder rather than moving the panel, if that's determined to be the 'only' option.

 

[malachi constant]

The door to the M/E room must have an specific size. You should have the same unobstructed space from the panel all the way to the door.

Imagine trying to get out of that room under that ladder if you we injured.

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I agree it would be less than ideal. Imagine trying to get out of a crawl space, or down a ship's ladder from up in a penthouse if you were injured. I'm interested in what code says about access to the space.

 

[malachi constant]

Photo attached. It's not pretty, but think my description is accurate. Also not sure how to rotate it...IMO it looks worse when looking at it on its side like this.

 

[REDICO]

He may call upon the following as his reference for the obstruction even though this is a 100 amp panel.

110.26 Spaces about Electrical Equipment says "as required or permitted elsewhere in this Code"

126(C)(2) Entrance to and Egress from Working Space Large Equipment (1200 amperes)
(a) Unobstructed Egress where the location permits a continuous and unobsrructrd way of egress travel, a a single entrance may be permitted."

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[malachi constant]

He may call upon the following as his reference for the obstruction even though this is a 100 amp panel.

110.26 Spaces about Electrical Equipment says "as required or permitted elsewhere in this Code"

126(C)(2) Entrance to and Egress from Working Space Large Equipment (1200 amperes)
(a) Unobstructed Egress where the location permits a continuous and unobsrructrd way of egress travel, a a single entrance may be permitted."

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That would be unfortunate on a couple different levels. Mainly that it wouldn't apply. It would be analogous to applying a restrictive section out of Article 517 (health care) to a school installation. You might want to make me put isolated ground outlets in the principal's office, but there is no code basis for it.

 

[JFletcher]

The HVAC duct is clearly in your horizontal working space. (110.26(A)2)).

 

[GoldDigger]

The HVAC duct is clearly in your horizontal working space. (110.26(A)2)).

It is not necessarily in the width of the access space if there is room on the unseen (left) side of the enclosure.

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[charlie b]

I would call this a violation, though I can’t think of an easy solution.

I base that on the requirement in 110.26(C)(1) that there be an entrance to the working space of sufficient area. Looking at 110.26(C)(3), I infer that the notion of “entrance to the working space” does not necessarily mean a door into the room. It is a matter of being outside the working space, and then entering the working space, and having an entrance available for that purpose. Judging by the photo, that entrance does not have sufficient area, no matter how you choose to interpret the word “sufficient.”

My best “not-at-all-easy” solution would be to make it possible to move the ladder out of the way, when access to the panel is needed. One way is to put hinges somewhere at or above head height, and include a rope and pulley system to swing it upwards. This, of course, would suddenly become problematic, if a medical team would have to come down that ladder, in order to get to a worker who was injured while working on the panel.

The “more-sensible-but-also-not-easy-and-certainly-not-cheap” solution would be to install a new panel somewhere else, and move the circuits over to the new panel.

 

[GerryB]

We have a project being held up for occupancy due to the building inspector objecting to the location of a 100A breaker panel. The panel is located in an M/E room which contains a tall ship's ladder. Imagine the ladder being about 18"~24" off the wall, you squeeze past it so now you are under it. The panel is located under here, on the same wall you squeezed past, tucked a few feet in from the ladder. There is no obstruction above, and there is adequate (more than code-minimum) working clearance in front of it. The door opens just fine. Etc. The electrical inspector was consulted on this prior to installation and had no problem with it. However it is now installed and the building inspector says there is "not adequate access into the room" and would like us to comment.

I oversimplified one thing about the existing space - after you squeeze past the stairs through that 18"~24" opening there is a vertical duct about 8" deep. Requires a taller person to duck a little as they go past it so their head doesn't hit the bottom side of the stairs. That said there are plenty of folks on site who are large and tall and none have issue squeezing back there.

I have personally had to crawl over/under/through some pretty challenging obstacles in my career to get to a panel. I can understand the desire to make panels more accessible, but this does not strike me as particularly onerous. That said if there is a code issue, be it electrical or building code, then code is code and we'll figure out somewhere else to move it. We are operating under 2014 NEC, all I can find is:
* 110.26 "Access and working space shall be provided and maintained about all electrical equipment to permit ready and safe operation and maintenance of such equipment." Equipment is broadly defined and many pieces of "equipment" are only maintainable in a crawl space or on a ladder.
* 110.26 (C) (1) "At least one entrance of sufficient area shall be provided to give access to and egress from working space about electrical equipment." Great. "Sufficient area." I read that as ""sufficient area to give access to and egress from working space..." which (depending on the exact definition of sufficient area" I would argue we have here.
* 110.26 (D) requires adequate illumination, I doubt there is a light under there. That is probably a necessary change to meet NEC.

If any of you have experience here please let me know. Thanks!

For what it's worth I would not be happy with the contradiction there with the BO. He asked you to "comment", so try to explain you met your codes, throw in the fact the EI said ok (which I'm sure you did) and see where it goes. It looks good to me. If a breaker trips it's not usually imperative to race right in there and fix it. I've seen much worse, I'm sure he has.

 

[kwired]

The door to the M/E room must have an specific size. You should have the same unobstructed space from the panel all the way to the door.

Imagine trying to get out of that room under that ladder if you we injured.

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With that logic if you had 10 foot wide by 10 feet tall space in front of the panel, then the door must also be 10 foot wide by 10 foot tall. What OP has wouldn't be any different if the door into that room were only 18-24 inches wide.

We have a project being held up for occupancy due to the building inspector objecting to the location of a 100A breaker panel. The panel is located in an M/E room which contains a tall ship's ladder. Imagine the ladder being about 18"~24" off the wall, you squeeze past it so now you are under it. The panel is located under here, on the same wall you squeezed past, tucked a few feet in from the ladder. There is no obstruction above, and there is adequate (more than code-minimum) working clearance in front of it. The door opens just fine. Etc. The electrical inspector was consulted on this prior to installation and had no problem with it. However it is now installed and the building inspector says there is "not adequate access into the room" and would like us to comment.

I oversimplified one thing about the existing space - after you squeeze past the stairs through that 18"~24" opening there is a vertical duct about 8" deep. Requires a taller person to duck a little as they go past it so their head doesn't hit the bottom side of the stairs. That said there are plenty of folks on site who are large and tall and none have issue squeezing back there.

I have personally had to crawl over/under/through some pretty challenging obstacles in my career to get to a panel. I can understand the desire to make panels more accessible, but this does not strike me as particularly onerous. That said if there is a code issue, be it electrical or building code, then code is code and we'll figure out somewhere else to move it. We are operating under 2014 NEC, all I can find is:
* 110.26 "Access and working space shall be provided and maintained about all electrical equipment to permit ready and safe operation and maintenance of such equipment." Equipment is broadly defined and many pieces of "equipment" are only maintainable in a crawl space or on a ladder.
* 110.26 (C) (1) "At least one entrance of sufficient area shall be provided to give access to and egress from working space about electrical equipment." Great. "Sufficient area." I read that as ""sufficient area to give access to and egress from working space..." which (depending on the exact definition of sufficient area" I would argue we have here.
* 110.26 (D) requires adequate illumination, I doubt there is a light under there. That is probably a necessary change to meet NEC.

If any of you have experience here please let me know. Thanks!

Unfortunately the item I enlarged in that quote, is subject to AHJ interpretation on how to enforce it, as NEC does not give any specific dimensions, sort of like service conductors must land in the service disconnect "nearest the point of entry" in a building, you get all sorts of differences in how that is interpreted when you go from one AHJ territory to another.

 

[REDICO]

You totally misread the statement. If you have a 30" door you should have a 30" path.

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[REDICO]

That would be unfortunate on a couple different levels. Mainly that it wouldn't apply. It would be analogous to applying a restrictive section out of Article 517 (health care) to a school installation. You might want to make me put isolated ground outlets in the principal's office, but there is no code basis for it.

It isn't pulling from a different article. This article is dealing with working clearance just of a different voltage. It states clearly that other parts of the Code may apply as determined by the AHJ.

I wouldn't have placed the panel in that location. If it was on a print, I would have requested an RFI from the architect or engineer before I installed it.

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[kwired]

You totally misread the statement. If you have a 30" door you should have a 30" path.

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OK, from the other way, garage or other building with an overhead door 18 feet wide, now we need 18 foot path all the way to any equipment requiring working space?

I guess OP can have the door to the room changed to an 18 or 24 inch door (whatever that space between ladder and wall is) and then he is good to go.

What if I have a 42 inch door on the mechanical/electrical room, but the nearest exterior door beyond that is only a 36 inch door?

I can see an AHJ going with something like what you mentioned as the way they choose to enforce it, but NEC alone does not give us any specific dimension or other egress requirement until we get into the items covered by (C)(2).

 

[charlie b]

Note to REDICO and Kwired: Why are you debating about the door? The door is not relevant to the issue. The thing that has to have "sufficient area" is not the door, it is the "entrance to the working space."

 

[kwired]

Note to REDICO and Kwired: Why are you debating about the door? The door is not relevant to the issue. The thing that has to have "sufficient area" is not the door, it is the "entrance to the working space."

I agree and will say egress routes beyond the working space boundary is not covered by NEC, they boundary maybe is a little different for large equipment (1200 amp+) but you ultimately still get to a boundary where NEC doesn't apply anymore.

 

[petersonra]

Note to REDICO and Kwired: Why are you debating about the door? The door is not relevant to the issue. The thing that has to have "sufficient area" is not the door, it is the "entrance to the working space."

Minimum Required. At least one entrance of sufficient
area shall be provided to give access to and egress
from working space about electrical equipment.

IMNSHO, if you can get past the stairs somehow that is sufficient. The only thing that is required is access, not ready access.

Accessible (as applied to equipment). Admitting close
approach; not guarded by locked doors, elevation, or other
effective means.

Accessible, Readily (Readily Accessible). Capable of being
reached quickly for operation, renewal, or inspections
without requiring those to whom ready access is requisite
to climb over or remove obstacles or to resort to portable
ladders, and so forth.

I don't see how the stairs are an effective guard are preventing access. It's a nuisance but it's not effective at preventing access. ready access even gives an example of something that is not readily accessible - having to climb over an obstacle. that suggests the obstacle can be there and you still have access, just not ready access.

While entrance is not defined in the NEC, it is defined in another NFPA code (5000 - whatever that is).

Entrance (Accessibility) Any access point to a building or facility, or portion of a
building or facility, used for the purpose of entering,
including the approach walk, the vertical access leading to the
entrance platform, the entrance platform itself, the vestibule,
if provided, the entry door or gate, and the hardware of the
entry door or gate.

That definition suggests an entrance requires a door or gate.

I do not think this situation is a NEC violation. It might violate some other code, and could be considered some kind of safety hazard but not a NEC violation.

 

[malachi constant]

IMNSHO, if you can get past the stairs somehow that is sufficient. The only thing that is required is access, not ready access.

Bob, I was very pleased to read this until I started down the path of writing an email defining "accessible" and "readily accessible". I thought I would google a comparison of those NEC definitions to get some more commentary, and ran across 240.24 - Overcurrent Protection - Location in or on Premises. Basically OCPDs must be readily accessible.

Going back to the definition of readily accessible, it states you shouldn't need to climb over something etc. I don't think we have "ready access". I think this could be construed as a violation. It is certainly an area up for interpretation, and the electrical inspector was consulted prior to installation and signed off on it, so there's that.

Tough situation to be in. I am the signing engineer and although I made many field visits during design my designer ultimately picked this location. I was not aware (until a few days ago) that this location was tucked under a stair. I am an engineer, which is good and all, but it doesn't make me omniscient over every decision that designers make. I took over CA for the project and it was never brought up to me, the Owner, or any of the design team members that there was a potential issue here until this week. I'd like to believe if there had been a concern brought up to me I would have done my due diligence (like I'm doing now) and said we should find another home for it. Or maybe I would have stopped my code research before I found 240.24 if I found out the electrical inspector was OK with it.

I think I will have to report that one could interpret the install to be a violation of 240.24, but note the code is gray area enough that when the electrical inspector was proactively consulted prior to installation he did not see a violation.

The contractor has been exceptional to work with, but I'm a little annoyed they didn't ask about this one. But in their shoes they went off the plans and the inspector said it was fine.

I'm also hearing that there is tons of other equipment under the stairs - Siemens controls etc. And what appears to be a disconnect. So there was precedent to put this under there.

Plenty of blame to go around here. One fallback solution may be to relocate the duct, which (if possible) would give us 16" clear and would mean you could walk back there without stooping & twisting. Owner is completely out of money and doesn't want to move it if they don't have to.

Thanks for all the comments. If I think to do it I'll come back and let you know how it got resolved. This place is such a great resource.

 

[petersonra]

Bob, I was very pleased to read this until I started down the path of writing an email defining "accessible" and "readily accessible". I thought I would google a comparison of those NEC definitions to get some more commentary, and ran across 240.24 - Overcurrent Protection - Location in or on Premises. Basically OCPDs must be readily accessible.

Going back to the definition of readily accessible, it states you shouldn't need to climb over something etc. I don't think we have "ready access". I think this could be construed as a violation. It is certainly an area up for interpretation, and the electrical inspector was consulted prior to installation and signed off on it, so there's that.

Tough situation to be in. I am the signing engineer and although I made many field visits during design my designer ultimately picked this location. I was not aware (until a few days ago) that this location was tucked under a stair. I am an engineer, which is good and all, but it doesn't make me omniscient over every decision that designers make. I took over CA for the project and it was never brought up to me, the Owner, or any of the design team members that there was a potential issue here until this week. I'd like to believe if there had been a concern brought up to me I would have done my due diligence (like I'm doing now) and said we should find another home for it. Or maybe I would have stopped my code research before I found 240.24 if I found out the electrical inspector was OK with it.

I think I will have to report that one could interpret the install to be a violation of 240.24, but note the code is gray area enough that when the electrical inspector was proactively consulted prior to installation he did not see a violation.

The contractor has been exceptional to work with, but I'm a little annoyed they didn't ask about this one. But in their shoes they went off the plans and the inspector said it was fine.

I'm also hearing that there is tons of other equipment under the stairs - Siemens controls etc. And what appears to be a disconnect. So there was precedent to put this under there.

Plenty of blame to go around here. One fallback solution may be to relocate the duct, which (if possible) would give us 16" clear and would mean you could walk back there without stooping & twisting. Owner is completely out of money and doesn't want to move it if they don't have to.

Thanks for all the comments. If I think to do it I'll come back and let you know how it got resolved. This place is such a great resource.

I agree it is a gray area. personally I would not want it there, but moving it or doing anything that would substantially improve access is a problem. I had forgotten that OCPD require ready access, and was responding to Charlie's comment from article 110. I don't know if this is readily accessible or not.