Smoke Damper Actuators

[WGMILLS1]

My project has several 120 V smoke damper actuators which are mounted to the damper's NFPA rated metal sleeve above the ceiling. The actuator is roughly 4" x 6" x 4" deep. Generally if this unit needs servicing,the whole actuator can be removed within the space 12" from the unit. The Engineer's comments state that there must be a 36" access in front of this unit per NEC similar to an air handler's service panel because the unit is 120V, but if it was 24 V this would not be required.
What would be your interpretation? Thanks

 

[acrwc10]

110.26(a) 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), (A)(2), and (A)(3) or as required or permitted elsewhere in this Code.

can maintenance be done while not energized ?

 

[Volta]

My project has several 120 V smoke damper actuators which are mounted to the damper's NFPA rated metal sleeve above the ceiling. The actuator is roughly 4" x 6" x 4" deep. Generally if this unit needs servicing,the whole actuator can be removed within the space 12" from the unit. The Engineer's comments state that there must be a 36" access in front of this unit per NEC similar to an air handler's service panel because the unit is 120V, but if it was 24 V this would not be required.
What would be your interpretation? Thanks

I would think that it is debatable that the clerance is required, assuming that it not likely the equipment requires examination while energized, but if it does, 24 volts would require it just as 120 volts would, until the AHJ has written special permission for smaller space 110.26(A)(1)(b).