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Working space for hot tub

Mr. Inspector

Mr. Inspector

SAWHORSE
Joined
Nov 28, 2009
Messages
4,107
Location
Poconos/eastern PA
2018 IRC
Plan indicates a deck surrounding a hot tub. Hot tub will be on the ground and the Deck will be 3' high above the ground. Wouldn't this violate the requirement for a minimum of a 6' high working space for the pump/heater/ panel in the hot tub? Is there a way to have a deck around a hot tub like this and not violate the required working space?
 
110.26 Spaces About Electrical Equipment. Access and working space shall be provided and maintained about all electrical equipment to permit ready and safe operation and maintenance of such equipment.

Accessible (as applied to equipment). Capable of being reached for operation, renewal, and inspection.

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)
 
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Mr. Inspector said:
2018 IRC
Plan indicates a deck surrounding a hot tub. Hot tub will be on the ground and the Deck will be 3' high above the ground. Wouldn't this violate the requirement for a minimum of a 6' high working space for the pump/heater/ panel in the hot tub? Is there a way to have a deck around a hot tub like this and not violate the required working space?
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2018 IRC:

E3405.2 Working clearances for energized equipment and
panelboards. Except as otherwise specified in Chapters 34
through 43, the dimension of the working space in the direction
of access to panelboards and live parts of other equipment
likely to require examination, adjustment, servicing or maintenance
while energized shall be not less than 36 inches (914
mm) in depth. Distances shall be measured from the energized
parts where such parts are exposed or from the enclosure front
or opening where such parts are enclosed. In addition to the 36-
inch dimension (914 mm), the work space shall not be less than
30 inches (762 mm) wide in front of the electrical equipment
and not less than the width of such equipment. The work space
shall be clear and shall extend from the floor or platform to a
height of 6.5 feet (1981 mm) or the height of the equipment,
whichever is greater. In all cases, the work space shall allow at
least a 90-degree (1.57 rad) opening of equipment doors or
hinged panels. Equipment associated with the electrical installation
located above or below the electrical equipment shall be
permitted to extend not more than 6 inches (152 mm) beyond
the front of the electrical equipment. [110.26(A) (1), (2), (3)]

Exceptions:

1. In existing dwelling units, service equipment and
panelboards that are not rated in excess of 200
amperes shall be permitted in spaces where the height
of the working space is less than 6.5 feet (1981 mm).
[110.26(A)(3) Exception No. 1]

2. Meters that are installed in meter sockets shall be permitted
to extend beyond the other equipment. Meter
sockets shall not be exempt from the requirements of
this section. [110.26(A)(3) Exception No. 2]
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Might this fall under Exception #1?
 
mtlogcabin said:
Adding or replacing a sign is not within the scope of the IEBC.

[A] 101.2 Scope.
The provisions of this code shall apply to the repair, alteration, change of occupancy, addition to and relocation of existing buildings.
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Yankee Chronicler said:
2018 IRC:



Might this fall under Exception #1?
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That is what I am trying to figure out. It is not in the existing dwelling unit. The house is existing, but it's outside under the new deck and in the new hot tub.

Not sure if the panel inside the hot tub would be defined as a panelboard. (No definition of panelboard in the IRC or NEC)

E3405.4 Outdoor dedicated panelboard space. The outdoor
space equal to the width and depth of the panelboard,
and extending from grade to a height of 6 feet (1829 mm)
above the panelboard, shall be dedicated to the electrical
installation. Piping and other equipment foreign to the electrical
installation shall not be located in this zone.
 
My house (originally built for my parents in 1950) has a main disconnect on the inside of the exterior wall of the garage, a breaker panel (originally a fuse panel) in the inside wall of the garage, and a well pump with a fused disconnect switch in the basement. Of those three disconnecting means, I would consider only the circuit breaker panel to be a "panelboard." The other two are disconnects.

What kind of "panel" is in (under) the hot tub? What functions does it serve? (Is it a thermostatic controller as well as a disconnect?) What does the manufacturer of the device list it as on their web site? (Not the manufacturer of the hot tub, the manufacturer of the "panel".)
 
Copied this from this web site above:

The National Electrical Code® (NEC®) defines a as a single panel or group of panel units designed for in the form of a single panel, including buses and automatic overcurrent devices, and equipped with or without switches for the control of light, heat, or power circuits; designed to be placed in a or placed in or against a wall, partition, or other support; and accessible only from the front (Article 1 00-Definitions).

The panel in every hot tub I ever saw does all of the above.

I brought this up because I had to lay on my belly to slide under a deck where the joists were only 2' above the ground to inspect the connections in the panel in the hot tub. Seems to me it would not be safe to work on it. We do not require a permit for a deck that is less than 30" above the ground like this one but we do require permits for hot tubs. This hot tub sits on the ground and is surrounded by the deck. I just want to see if I am justified in requiring for them to move the hot tub or tear down part of the deck for a working space.
 
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Mr. Inspector said:
I brought this up because I had to lay on my belly to slide under a deck where the joists were only 2' above the ground to inspect the connections in the panel in the hot tub. Seems to me it would not be safe to work on it. We do not require a permit for a deck that is less than 30" above the ground like this one but we do require permits for hot tubs. This hot tub sits on the ground and is surrounded by the deck. I just want to see if I am justified in requiring for them to move the hot tub or tear down part of the deck for a working space.
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I would say yes.
 
Mr. Inspector said:
I don't know about all of them, but my own spa has a couple of small fuses. I only know because a repair person had to replace one once.
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OK, but that doesn't make it a panelboard. A panelboard is something listed to UL67 and installed as part of the premises wiring system. The circuit breakers or fuses in a panel board are for branch circuit protection. The hot tub is utilization equipment, and its internal fuses are for last-ditch protection of its components.

If you are applying E3405.2, then obviously you need to interpret what "equipment likely to require examination, adjustment, servicing or maintenance while energized" means. One interpretation is that it would apply to all equipment, but that is obviously problematic since, for example, kitchen counter receptacles can't comply with the working space requirements.

So the usual interpretation is that it applies just to panelboards and possibly equipment disconnects, and not to the equipment itself. If the hot tub blows a fuse, that can be trouble checked without power to the hot tub, just put an ohmmeter across the fuse.

Applying E3405.2 working space requirements to a hot tub is a huge stretch. Edit: the installation manual for the hot tub may call out certain clearances around the hot tub (such as in front of the side panel that covers the electrical equipment), and that could be enforced via NEC 110.3(B).

Cheers, Wayne
 
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wwhitney said:
OK, but that doesn't make it a panelboard. A panelboard is something listed to UL67 and installed as part of the premises wiring system. The circuit breakers or fuses in a panel board are for branch circuit protection.
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I can't find anywhere in the IRC that says this. Maybe there should be a definition.

I asked the repairman shouldn't he turn off the breaker before he worked on my spa, and he said he needed it on to start to service it. He said the first thing he wanted to check is to see if any power was going into the panel in the spa. I wouldn't know, I never worked on one. He didn't know if it was a fuse at the time. I'm sure he was glad that there was working space, and that side of the spa was not against a wall.

I may be wrong, but I need more convincing, and I am open for it. I just rather be safe than sorry.
 
wwhitney said:
Applying E3405.2 working space requirements to a hot tub is a huge stretch. Edit: the installation manual for the hot tub may call out certain clearances around the hot tub (such as in front of the side panel that covers the electrical equipment), and that could be enforced via NEC 110.3(B).
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110.3(B) Installation and Use. Equipment that is listed, labeled, or both shall be installed and used in accordance with any instructions included in the listing or labeling.

If 110.3(B) didn't get you there 110.12 could. The fact that you did a belly crawl with a 24" clearance doesn't bolster the contention that the work is not workmanlike. I would have refused. If there were a problem with a code section I would still refuse to crawl...I'm pretty sure that most workmen would do the same. A section of the deck should be built so that it is easily lifted out to provide sufficient access to the tub pump/motor/over-current devices/etc....

110.12 Mechanical Execution of Work. Electrical equipment shall be installed in a neat and workmanlike manner.
 
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Mr. Inspector said:
I can't find anywhere in the IRC that says this. Maybe there should be a definition.
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The IRC has a definition of panelboard in Chapter 35. "PANELBOARD. A single panel or group of panel units designed for assembly in the form of a single panel, including buses and automatic overcurrent devices, and equipped with or without switches for the control of light, heat or power circuits, designed to be placed in a cabinet or cutout box placed in or against a wall, partition or other support and accessible only from the front."

The terminal board in your hot tub where the installer lands the branch circuit conductors is not a panelboard. It's not a panel, it's whatever shape fits conveniently in the equipment. It does not have buses in the usual sense of the electrical code, it just has traces on circuit boards. It is not designed to be placed in a cabinet or cutout box placed in or against a wall, it is designed to got in whatever space under the hot tub is convenient for the manufacturer's design.

Cheers, Wayne
 
wwhitney said:
The IRC has a definition of panelboard in Chapter 35. "PANELBOARD. A single panel or group of panel units designed for assembly in the form of a single panel, including buses and automatic overcurrent devices, and equipped with or without switches for the control of light, heat or power circuits, designed to be placed in a cabinet or cutout box placed in or against a wall, partition or other support and accessible only from the front."

The terminal board in your hot tub where the installer lands the branch circuit conductors is not a panelboard. It's not a panel, it's whatever shape fits conveniently in the equipment. It does not have buses in the usual sense of the electrical code, it just has traces on circuit boards. It is not designed to be placed in a cabinet or cutout box placed in or against a wall, it is designed to got in whatever space under the hot tub is convenient for the manufacturer's design.

Cheers, Wayne
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I don't know why I don't get it.
1. There is nothing about the shape of a panel in the definition.
2. I don't know the difference between the buses in the spa panel and the usual sense of the electrical code. It meets the definition of a Current-Limiting Overcurrent Protective Device in NEC 240.2.
3. It is designed to have other support.
4. It is accessible only from the front.
5. It is equipped with switches for control of light, heat and power.

But I am willing to not call it a panelboard, but it won't change the required Working Space for electrical equipment. This may be an existing dwelling unit and I know existing dwelling units have an exception on the height for working space, but this is a deck that was built after or the same time as the spa was installed. Does this make a difference? It just doesn't seem safe for someone to slide on their stomach to work on the electrical parts of the spa.
 
Mr. Inspector said:
I don't know why I don't get it.
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It may just be that the definition is poor and doesn't provide sufficient clarity to the unfamiliar. But the term panelboard is not meant to cover every piece of equipment that has a fuse in it. It is meant to cover certain classes of equipment whose primary purpose is to contain overcurrent devices. So the definition is focused on distinguishing from other classes of such equipment (e.g. switchgear), not distinguishing from utilization equipment.

Mr. Inspector said:
It just doesn't seem safe for someone to slide on their stomach to work on the electrical parts of the spa.
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If we accept that the hot tub doesn't have a panelboard, then the definite portion of E3405.4 does not apply, and we are left with "live parts of other equipment likely to require examination, adjustment, servicing or maintenance while energized."

How to apply that has always been open to interpretation. But I have not seen it applied to utilization equipment. How is the hot tub surrounded by a deck different from a stacked washer/dryer in a closet or a built-in refrigerator?

As to your initial question "Is there a way to have a deck around a hot tub like this and not violate the . . . working space?" (where I omitted required, as I don't believe it's required), the deck could have a removeable hatch in one or two key areas to provide more headroom.

Cheers, Wayne
 
wwhitney said:
How to apply that has always been open to interpretation. But I have not seen it applied to utilization equipment. How is the hot tub surrounded by a deck different from a stacked washer/dryer in a closet or a built-in refrigerator?
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A washer dryer can be moved. This spa cannot be moved without some demolition. But if you are calling it an appliance maybe I should go by the 2017 IMC and the opening should be as big as the spa?

306.4 Appliances under floors. Underfloor spaces containing
appliances shall be provided with an access opening and
unobstructed passageway large enough to remove the largest
appliance. The passageway shall be not less than 30 inches
(762 mm) high and 22 inches (559 mm) wide, nor more than
20 feet (6096 mm) in length measured along the centerline of
the passageway from the opening to the appliance. A level
service space not less than 30 inches (762 mm) deep and 30
inches (762 mm) wide shall be present at the front or service
side of the appliance. If the depth of the passageway or the
service space exceeds 12 inches (305 mm) below the adjoining
grade, the walls of the passageway shall be lined with
concrete or masonry. Such concrete or masonry shall extend
not less than 4 inches (102 mm) above the adjoining grade
and shall have sufficient lateral-bearing capacity to resist collapse.
The clear access opening dimensions shall be not less
than 22 inches by 30 inches (559 mm by 762 mm), and large
enough to allow removal of the largest appliance.
Exceptions:
1. The passageway is not required where the level service
space is present when the access is open and the
appliance is capable of being serviced and removed
through the required opening.
2. Where the passageway is unobstructed and not less
than 6 feet high (1929 mm) and 22 inches (559 mm)
wide for its entire length, the passageway shall not
be limited in length.
306.4.1 Electrical requirements. A luminaire controlled
by a switch located at the required passageway opening
and a receptacle outlet shall be provided at or near the
appliance location in accordance with NFPA 70.
 
Mr. Inspector said:
But if you are calling it an appliance maybe I should go by the 2017 IMC and the opening should be as big as the spa?
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You would know the building codes definitions better than I would, but I wouldn't think a deck is the same as a floor, nor an underdeck space the same as an underfloor space.

Cheers, Wayne
 
Well, there is not a definition of a floor or a deck in the code, but the code requires a floor on a deck on the exterior side of a door and a floor on top a stairway on a deck. Also, the deck sections are in Chapter 5 "Floors". If someone said the floor on my deck is getting too rough, what part of the deck do you think they would mean? So, my conclusion is that the top surface on a deck is a floor. Is this wrong?
 
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