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It depends on if it is likely to require examination, adjustment, servicing, or maintenance while energized.

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Google up NFPA 72 if memory serves not to the letter of 110.26(A) but must Be readily accessible
 
It depends on if it is likely to require examination, adjustment, servicing, or maintenance while energized.

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I don't do Fire alarm panels but, like Wlaricci said, If you can't de-energize it to work on it then yes you would have to have 110.26 clearance.
 
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