GFCI Readily Accessible for Electric Water Cooler (NEC 2014 422.52)

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tw1156,

In reading your OP, I'm thinking that you [ may ]
be mixing apples & oranges with your question.

If you are asking if the Water Cooler, GFCI required
receptacle is "readily accessible" according to the
NEC, then I would probably say "Yes !"..........If, on
the other hand, you are asking if the owner, or
others restricted to a wheelchair, could access the
receptacle underneath the Water Cooler, according
to the `10 ADA Standards for Accessible Design, I
would say probably not.

Refer to Section 308.2.1, in the `10 A.D.A.S.A.D.
iu
iu




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I believe Charlie B initially provided an excellent answer mentioning 90.1(B), but I believe their core definition of readily accessible is what threw me in a loop in the first place in thinking of who they define as their typical person. I'm thinking, along the lines Charlie B originally mentioned, that the NEC will defer to more stringent codes (ADA) to provide updated information relating to what they define as accessible. If this is the case, the ADA requirements could place a more stringent interpretation of the code, depending on when you apply their design requirements. The NEC would have a very difficult time trying to place design requirements for all the types of people out there (short, tall, wheelchair bound, blind, etc)

Thank you for the visual North Star, this is a great representation at what I was trying to explain.
 
tw1156 said:
I believe Charlie B initially provided an excellent answer mentioning 90.1(B), but I believe their core definition of readily accessible is what threw me in a loop in the first place in thinking of who they define as their typical person. I'm thinking, along the lines Charlie B originally mentioned, that the NEC will defer to more stringent codes (ADA) to provide updated information relating to what they define as accessible. If this is the case, the ADA requirements could place a more stringent interpretation of the code, depending on when you apply their design requirements. The NEC would have a very difficult time trying to place design requirements for all the types of people out there (short, tall, wheelchair bound, blind, etc)

Thank you for the visual North Star, this is a great representation at what I was trying to explain.
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Now if this water cooler is in the lobby of a public access building, does any authority expect the person in a wheel chair to be able to access the GFCI?

ADA accessibility to use the water cooler is understandable, but I doubt in this location they expect ADA to apply to accessibility of the GFCI supplying the water cooler. In fact anyone inspecting for ADA compliance probably never says a word if the receptacle is within the water cooler assembly but if it is visible outside the assembly, may want it high enough to be ADA compliant for general use receptacles.
 
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Placement of the GFCI rated receptacle is not extremely critical in
the NEC realm, however, in the ADA Litigious Landscape of today,
...placement and access to that receptacle may be "Lawsuit Worthy"
"IF" ADA employees need access to it.

Perhaps, another more easily reached location could be designed
before the circuits are installed........Aesthetics be damned to
protect against a lawsuit.

Yeah, it IS that crazy in the ADA enforcement world of today ! :cry:


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north star said:
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Placement of the GFCI rated receptacle is not extremely critical in
the NEC realm, however, in the ADA Litigious Landscape of today,
...placement and access to that receptacle may be "Lawsuit Worthy"
"IF" ADA employees need access to it.

Perhaps, another more easily reached location could be designed
before the circuits are installed........Aesthetics be damned to
protect against a lawsuit.

Yeah, it IS that crazy in the ADA enforcement world of today ! :cry:


@ ~ @ ~ @
Click to expand...
Now consider the fact that the GFCI could be circuit breaker type in a room not accessible to the person in question anyway:roll:

Does anyone ever use common sense anymore? If the thing trips it is probably a maintenance man that needs to have access to it, not patrons of the facility.
 
OCPD installed up to 6'7" accessible?

OCPD installed up to 6'7" accessible?

I agree that a GFCI breaker would solve the problem of being accessible, but still only accessible to able-bodied people. Depending on the panel specified, breakers could be well above 48" and not "accessible" to people of wheel chairs.

I think we're in the realm of 'what-ifs', but it's still a valid discussion nonetheless as it wasn't long ago that people did not provide much merit for meeting ADA accessibility when it first came out. In looking at 240.24(A) and (B) in reference to location and accessibility of overcurrent devices, it references that overcurrent devices may not be installed more than (6ft 7in); this would leave 2ft-7in not accessible to the occupant, if they are wheelchair bound. 240.24(B) references that "each occupant shall have ready access to all overcurrent devices protecting the conductors supplying that occupancy, unless otherwise permitted in 240.24(B)(1) and (2). Basically, the owner/tenant/etc, if wheelchair bound, would not have access to a GFI breaker if it was installed above 48"(or out of reach as deemed by ADA), and thus they are just out of luck until a maintenance/or hired electrician is brought in to flip the switch. Perhaps this is to only mean access to the room location of the OCPD, and not necessarily the overcurrent protective device...which seems ludicrous, but perhaps that is the current meaning.

I want to believe this to be a non-issue at the moment, but as North Star pointed out, there may be room in the future for potential lawsuits and it'd be preferred to have the bases covered.

Thank you all for your time.
 
tw1156 said:
I agree that a GFCI breaker would solve the problem of being accessible, but still only accessible to able-bodied people. Depending on the panel specified, breakers could be well above 48" and not "accessible" to people of wheel chairs.
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I am with you and in my post directly above I was talking about an outlet behind removable panels and NEC requirements.


I understand in your situation the receptacle is not behind panels so in my opinion the NEC is satisfied.

As far as ADA, it is what it is. Constantly getting broader, being applied to more areas etc. I try not to get to bothered by it.

When I see a sign in an office building that says 'Coat Closet' in braille it does make me wonder how they find their coat etc.


Compliance could be very costly and complicated Consider a great many electrical panelboards, controls, switchgear, disconnecting means, etc. are located in areas that are not wheelchair accessible by a long shot.

Should all electrical equipment in say a factory be able to be serviced by a person with a disability that limits them to the ADA reach limits?

How would that be done, who is footing the bill for all that would be involved?
 
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tw1156 said:
Just curious, but hypothetically, if the facility is designed to be ADA accessible, and the owner is wheelchair bound, would that not place that receptacle out of reach? As designs require us to factor in all patrons (switch height max of 48", ADA accessible water coolers, etc), would this not be a gray area that is not fully addressed or am I overthinking this?
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I would say you are overthinking it. If we took your scenario and extended it, then all circuit breakers would have to be mount 48" or below to be ADA accessible, not just a GFCI for a water cooler.
 
Good points iWire, Strathead, and it does bring out the whole where does it stop to accommodating everyone. Has anyone come across a design specifically for ADA (apartment, house, commercial, other location etc), where this was an issue? If not, perhaps the topic has been thoroughly discussed and we can leave it at that as a non-issue for the moment.
 
Let's throw vending machines in to this mix. I don't believe there has been a push for vending machine GFI's to be located outside of their footprint, and as with water coolers NOTHING stops an occupant from putting a piece of furniture right in front of a GFI located to the side. This is really another case of the code wanting something specific but not having the guts to just require it. Rather than all this pussy footing around they should just flat out state they need to be fed form a GFI style breaker and be done with it.
 
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While typically in the past, not much consideration has been given
to the actual location of various devices, switches and other
elements on a property, the lawsuit driven environment in which
we operate forces us, Contractors and especially the owners, to give
serious consideration to ALL aspects of anything ADA related.

Yes, the Contractors are supposed to install [ only ] what has been
approved by the RDP & the construction plans, but again, because
of the litigious environment in which is present these days, IMO
everyone should become familiar with the ADA regs.......The lawsuits
are not going away any time soon, in fact, ...in some areas of the
country, it appears as though they are in fact increasing.

Yes, ...in the past it was not this way, but times have changed.
Whether or not you consider the various nuances of Reach Ranges,
location of switches, breakers, outlets and on and on and on
important or not, I can assure you ALL that there are individuals
out there who are thinking about this every single day, just looking
for something to sue someone over, and the ADA legislation
& Standards provide them with just such a means to do it.

Remember, ...Coverest Thy Arse ! :happyyes:



tw1156,

Unfortunately, the ADA Standards cannot & WILL NOT be left alone
as a "non-issue".........There is too much [ potential ] for winning
a dollar amount in court.

The world of the "built environment" cannot afford to turn a blind
eye to the ADA.


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tw1156 said:
Good points iWire, Strathead, and it does bring out the whole where does it stop to accommodating everyone. Has anyone come across a design specifically for ADA (apartment, house, commercial, other location etc), where this was an issue? If not, perhaps the topic has been thoroughly discussed and we can leave it at that as a non-issue for the moment.
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I don't know ADA codes all that well, but would think a dwelling that is intended to comply might require things like circuit breakers to comply. But a public access building and ADA requirements you would think would only apply to things they intend the person with a disability to have access to. Does anyone that comes into a public access building need access to the overcurrent devices or just the building owner or staff need access to such things? Is the receptacle below the drinking fountain and for the drinking fountain in such a place something any guest needs to have access to, let alone someone in a wheel chair? If drinking fountain were in a dwelling that might be different, though I bet in an ADA compliant home you still end up with receptacles dedicated to an appliance that are not necessarily ADA accessible.
 
tw1156 said:
Good points iWire, Strathead, and it does bring out the whole where does it stop to accommodating everyone. Has anyone come across a design specifically for ADA (apartment, house, commercial, other location etc), where this was an issue? If not, perhaps the topic has been thoroughly discussed and we can leave it at that as a non-issue for the moment.
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The companies I have worked for have done apartment buildings, assisted living facilities etc. and often in the ADA rooms the panelboard will be mounted within ADA heights to comply with the NEC code sections you have mentioned. Full time access and within their reach.

But the entire suite will have accommodations like sinks you can bring a wheel chair under, stove tops as well. Different shower / bathtubs as well.
 
Strathead said:
Let's throw vending machines in to this mix. I don't believe there has been a push for vending machine GFI's to be located outside of their footprint,
Click to expand...

Here we would not locate one behind the vending machine. I would expect to fail inspection for that.


and as with water coolers NOTHING stops an occupant from putting a piece of furniture right in front of a GFI located to the side.
Click to expand...

There is never anything to stop any future changes to anything we do. What maters is how it is when I have the inspector come out.
 
Strathead said:
.... This is really another case of the code wanting something specific but not having the guts to just require it. Rather than all this pussy footing around they should just flat out state they need to be fed form a GFI style breaker and be done with it.
Click to expand...

I don't think there was a secret push for gfci breakers that fell short. I do think all this difficulty of interpretation comes about every time the NEC gets involved in a design criteria and I really wish they would stop.
 
iwire said:
Here we would not locate one behind the vending machine. I would expect to fail inspection for that.
Click to expand...


Not doubting, but a typical vending installation has three or four machines side by side on a wall with little extra horizontal space. I haven't done any recently, but one has to wonder..
 
ActionDave said:
I don't think there was a secret push for gfci breakers that fell short. I do think all this difficulty of interpretation comes about every time the NEC gets involved in a design criteria and I really wish they would stop.
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I know, I was simplifying. What I expect is they don't want to be too specific, and in the vagueness create additional problems. At the same time requiring them to be GFI breakers would also have repercussions with old panels that don't have GFI breakers available.
 
ActionDave said:
I don't think there was a secret push for gfci breakers that fell short. I do think all this difficulty of interpretation comes about every time the NEC gets involved in a design criteria and I really wish they would stop.
Click to expand...

I have to agree. I don't see what ready access to a GFCI has to do with safeguarding of persons and property from hazards arising from the use of electricity. If it trips the hazard was removed, it don't care if it was accessible or not to be able to trip. I imagine they played the "users need to test them periodically" card to help get the requirement in there.

I still think this should be a design decision.
 
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