Gfi outlet accessible in appliance garage?

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Stevenfyeager

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United States, Indiana
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electrical contractor
Is a gfi outlet considered readily accessible inside an appliance garage? I had one inspector fail a kitchen gfi outlet inside a cabinet with a toaster plugged in. I'm not sure about an appliance garage, which would be very similar. Thank you.
 
If you go by the letter of the code the inspector could be correct. If the gfci were located where you didn't have to remove appliances then he would not be correct. Imo, that is a tough call from the inspector. I would pass it but--I don't matter

Accessible, Readily (Readily Accessible). Capable of being
reached quickly for operation, renewal, or inspections without
requiring those to whom ready access is requisite to take
actions such as to use tools (other than keys), to climb over or
under, to remove obstacles, or to resort to portable ladders,
and so forth
 
not sure if the others got the Q.

an "appliance garage" so some sort of box on counter, with perhaps accordion style door that closes down. a gfi recept in there should be perfectly fine under NEC as you are not having to remove anything to get to it. removal is like taking screws out, needing a forklift, needing 2 people, etc etc. an obstacle is something that hinders progress. sliding a toaster or blender out of the way is not an obstacle.
 
not sure if the others got the Q.

an "appliance garage" so some sort of box on counter, with perhaps accordion style door that closes down. a gfi recept in there should be perfectly fine under NEC as you are not having to remove anything to get to it. removal is like taking screws out, needing a forklift, needing 2 people, etc etc. an obstacle is something that hinders progress. sliding a toaster or blender out of the way is not an obstacle.

Where does it state that removal means like taking out screws or using a forklift? I agree the appliance garage should not be an issue but I can see where an inspector can call you on it. Same is true under a sink where the gfci is shoved all the way in the back and you have to remove all the kitchen cleaners, sponges dishwasher detergent etc. It is an AUTHORITY HAVING JURISDICTION call.
 
Where does it state that removal means like taking out screws or using a forklift?

So where do you draw the line?
No counter top receptacle location should ever be acceptable. After all it is likely that the counter top will have something on it, like an old pizza box or maybe a pile of wet laundry, that needs to be removed. On second thought, I bet a case can be made that any plug inserted into a receptacle actually renders it inaccessible.
 
The question concerns 'accessible'.

Fortunately, the NEC covers this in Art. 100.

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

I would not consider the toaster, coffee maker or bread machine that's inside the garage an 'obstacle' any more than the door to a bedroom an obstacle to the panel behind it. if you're going to be that hard-nosed about it, then you won't be able to put anything on the counter directly in front of the receps that serve it. No soap dispensers, no utensil containers, no knife racks, no paper towel dispensers, no cutting boards, no dish-drying racks, no potpourri jars, no serving trays, no silverware racks, ...........

Heck, one might argue that the countertop itself is an obstacle that must be leaned over to access the device.

Where does it state that removal means like taking out screws or using a forklift? ..........

See the above quote.
 
This rule is based on the need to test the GFCI. Current GFCIS are self testing...this rule may not be needed but I don't see it going away
 
The question concerns 'accessible'.

Fortunately, the NEC covers this in Art. 100.



I would not consider the toaster, coffee maker or bread machine that's inside the garage an 'obstacle' any more than the door to a bedroom an obstacle to the panel behind it. if you're going to be that hard-nosed about it, then you won't be able to put anything on the counter directly in front of the receps that serve it. No soap dispensers, no utensil containers, no knife racks, no paper towel dispensers, no cutting boards, no dish-drying racks, no potpourri jars, no serving trays, no silverware racks, ...........

Heck, one might argue that the countertop itself is an obstacle that must be leaned over to access the device.



See the above quote.

I still don't see those words-- screwdrivers would fall under tools--

I don't necessarily agree with it but I have heard of people getting nailed for this type install.
 
I still don't see those words-- screwdrivers would fall under tools--

I don't necessarily agree with it but I have heard of people getting nailed for this type install.

You want a phonebook-size list of possible tools that would fall under the NEC's blanket wording?

Would your hands & arms used to move the appliance be considered falling under tools?
 
You want a phonebook-size list of possible tools that would fall under the NEC's blanket wording?

Would your hands & arms used to move the appliance be considered falling under tools?
No but my hand would be used to removed obstacles. We can argue this all day but in the end it is an authority having jurisdiction call whether you like it or not.
 
Where does it state that removal means like taking out screws or using a forklift? I agree the appliance garage should not be an issue but I can see where an inspector can call you on it. Same is true under a sink where the gfci is shoved all the way in the back and you have to remove all the kitchen cleaners, sponges dishwasher detergent etc. It is an AUTHORITY HAVING JURISDICTION call.

NFPA 70 does not supersede the English language.

ob·sta·cle

ˈäbstək(ə)l/
noun

noun: obstacle; plural noun: obstacles
a thing that blocks one's way or prevents or hinders progress.


if I need to remove screws, lift a heavy panel, need to assemble 10 people, or need a forklift, my progress is being hindered by the obstacle.

having to easily move something by myself (pizza box, spoon, small counter appliance, cereal box, etc etc), or in general terms "having reasonable expectation that most can access the [thing] without exorbitant effort", is the basis for the NEC definition.

i mean just take fridge as the base, the recept is way back there, one needs to slide out a "heavy" fridge, yet that recept is readily accessible even though some might claim the fridge itself is a obstacle. inspections are typically done w/o appliance in place anyways, so that 3k-lb hunk fridge that comes later that not one person can roll out by them-self is likely an obstacle.
 
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Am I the only one questioning this part:
. . . a kitchen gfi outlet inside a cabinet with a toaster plugged in.
Excuse me, but a toaster inside a cabinet? I may be envisioning this incorrectly, but I would tend to want to fail this as a fire hazard, notwithstanding any question of the accessibility of the receptacle.

 
Am I the only one questioning this part:Excuse me, but a toaster inside a cabinet? I may be envisioning this incorrectly, but I would tend to want to fail this as a fire hazard, notwithstanding any question of the accessibility of the receptacle.

how one becomes idiot-in-application does not apply to inspections under NEC code.

a GFI recept inside an "appliance garage" is what will be inspected. what goes in the garage later, be it a heavy hunk of concrete, a toaster oven, or a box of tissue, is (should be) of no concern to inspection.

that is way different than a GFI outlet stud mounted and properly wall board finished, and then a 17" wide x 2ft high piece of 5/8" ply screwed over the top of the recept using 5 screws top&bottom and 9 screws down each side, thus getting to the recept would in fact be a pita, not readily accessible, and the screws would be a nasty obstacle in the way.

appliance garage are storage locations, like a car in garage, but just like running your car in garage, should not do that and not run a toaster in the appliance garage, thus the appliance is typically pulled out for use, pushed back in the garage and door closed when not in use.
 
OK guys, stand by for some brilliance.

  1. The receptacle within the appliance garage is not readily accessible. No debates, please, and leave the AHJ out of this discussion. Reference NEC 210.52(C)(5), which states in part, “Receptacle outlets rendered not readily accessible by . . . appliance garages . . . .”
  2. The receptacle within the appliance garage is not required to be GFCI protected anyway. Reference the same NEC 210.52(C)(5), which says that that receptacle cannot be counted as a required countertop receptacle, coupled with NEC 210.8(A)(6), which requires GFCI for outlets in the kitchen that serve the countertop, which this one does not.

Ta Da! :cool:
 
This rule is based on the need to test the GFCI. Current GFCIS are self testing...this rule may not be needed but I don't see it going away

also, how does the rule apply if the ckt has gfci ocpd and the panel is outside and contains a Master lock to open the panel door?
 
Locked doors do not make an area "not readily accessible." Neither would a lock on a panel door.
 
OK guys, stand by for some brilliance.

  1. The receptacle within the appliance garage is not readily accessible. No debates, please, and leave the AHJ out of this discussion. Reference NEC 210.52(C)(5), which states in part, “Receptacle outlets rendered not readily accessible by . . . appliance garages . . . .”............

Too bad that portion refers to the required location and spacing of receptacles along the countertop, not whether it's considered accessible.

 
Too bad that portion refers to the required location and spacing of receptacles along the countertop, not whether it's considered accessible.
it does suggest appliance garages does make the recept not readily accessible.
edit - i take that back. the verbiage is odd. i think all 210.52c5 says is (in part), recept in appliance garage is not counted. the grammar used is bad.


OK guys, stand by for some brilliance.

  1. The receptacle within the appliance garage is not readily accessible. No debates, please, and leave the AHJ out of this discussion. Reference NEC 210.52(C)(5), which states in part, “Receptacle outlets rendered not readily accessible by . . . appliance garages . . . .”
  2. The receptacle within the appliance garage is not required to be GFCI protected anyway. Reference the same NEC 210.52(C)(5), which says that that receptacle cannot be counted as a required countertop receptacle, coupled with NEC 210.8(A)(6), which requires GFCI for outlets in the kitchen that serve the countertop, which this one does not.

Ta Da! :cool:

i suspect the "appliance garage" 210.52c5 speaks of is a permanent type, like attached to cabinet installation and thus cannot be moved at all. i think all it says is, that recept is not counted towards the required amount.
 
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Too bad that portion refers to the required location and spacing of receptacles along the countertop, not whether it's considered accessible.
The text appears in a paragraph for which the title has to do with spacing and location. But the words seem fairly clear to me that an appliance garage makes a receptacle "not readily accessible," which is the reason it can't be counted as one of the outlets required in the kitchen.

 
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