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Readily Accessible GFCI Required NEC 210.8

jar546

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There are many GFCI protected receptacles that must be readily accessible. If they are on a GFCI breaker then that is another story, the panel should be readily accessible anyway. What is your opinion on the following situations. Are the GFCI receptacles (with the test reset button on them) on this list accessible?

1) A GFCI receptacle for a microwave located in the back of the cabinet above it.
2) A GFCI receptacle located behind a stackable washer/dryer.
3) A GFCI receptacle beneath the kitchen sink on the back wall of a the cabinet for the dishwasher.
4) A GFCI receptacle on the ceiling of a garage for the door opener.
5) A GFCI receptacle located behind the refrigerator.

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. (CMP-1)
Informational Note: Use of keys is a common practice under
controlled or supervised conditions and a common alternative
to the ready access requirements under such supervised conditions
as provided elsewhere in the NEC.
 
You are correct that many of those locations you mentioned in your 1st post are not readily accessible. Other than GFCI breaker there are other possible solutions. Some of them, at don't mandate being a separate circuit could just be an extension of a GFCI circuit elsewhere. Once it require a separate circuit could still have a blank face GFCI outlet located in an accessible location. There are many solutions if you think outside the box.
 
A breaker is not always possible depending on the age and brand of the existing electrical panel. This is why I am asking this question specific to when a breaker is not used.
Add a subpanel that is accessible
 
So you're not going to answer the question? I was looking for some input.
IMPO readily accessible does not include relocation of appliances.
IMPO readily accessible is also so an 85 year old grandmother with mobility issues does not need to call in an electrician to reset it. But that's just me.
 
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