You can't be serious. A very bad NEC interpretation

[jar546]

Ok so this one has me riled up. The Building Officials Association of Florida (BOAF) of which I am a member came out with this informal interpretation that some people are hanging their hat on as gospel as though it is an official interpretation. I would love to send this to the NFPA to get their take on this. See the attached PDF.

Essentially, you know what? Just read it.

Here is my rebuttal.

1) Electricians and HVAC service technicians are always working in live disconnects taking voltage readings. Read 110.26. The interpretation only uses the word service and completely ignores the other verbiage in 110.26 such as examination, adjustment, & maintenance. I cannot for the life of me understand why you would render an opinion on a life safety item that is black and white with no gray area.

2) Does 110.26 really have to say disconnect? Isn't a disconnect electrical equipment? It is almost as though this interpretation was a favor to someone.

 

[ICE]

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.
(A) Working Space. Working space for equipment operating at 1000 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.

If a disconnect does not contain an overcurrent protective device, 110.26 does not apply. There is no need to adjust, service or maintain a disconnect and any examination can take place with the disconnect de-energized.

If the argument is presented that servicing HVAC might require access to the disconnect the obvious question is how about junction boxes that could also be be part of the installation. While a junction box is required to be accessible, 110.26 does not apply.

Remember, the only one of the four tasks that apply to a disconnect is examination. There is no need to examine a disconnect while it is energized.

That is the policy with the AHJ that employed me for 25 years... While I can see your point I can also see the other way to look at it.

 

[jar546]

If a disconnect does not contain an overcurrent protective device, 110.26 does not apply. There is no need to adjust, service or maintain a disconnect and any examination can take place with the disconnect de-energized.

A disconnect is a functioning piece of electrical equipment that is often opened and closed for the purpose of taking voltage readings, whether or not there is any OCPD inside. Hence the word examination. We open the disconnect and examine the wiring in order to take live voltage or current readings. 110.26 applies to AC disconnects.

 

[steveray]

I'm with ICE....unless we want to not allow switches over counters in the kitchen anymore.....But I am sick of stupid NEC stuff....

 

[ICE]

A disconnect is a functioning piece of electrical equipment that is often opened and closed for the purpose of taking voltage readings, whether or not there is any OCPD inside. Hence the word examination. We open the disconnect and examine the wiring in order to take live voltage or current readings. 110.26 applies to AC disconnects.

Do you open J-boxes to take readings? What about what steveray asked?

Electricians are like frustrated surgeons.....they need a theater to work in.

HVAC contractors are not electricians. They are willing to stand on their head and work with their toes.

You will not win this one Jeff. For starters, the opinion has already been disseminated. When was the last time something like this was taken back? They are not going to be embarrassed. And then there's you being wrong and all.

By the way, this is not the first time that we have agreed to disagree on this subject. The BOAF siding against you puts the ICEing on the cake hey.

 

[jar546]

Regardless of what you think or try to bring in junction boxes, the verbiage in the code is clear on this. This is not a discussion about junction boxes which don't have to be readily accessible. There is no winning. Every state and jurisdiction I worked in all enforce 110.26 the same way when it comes to AC disconnect which has moving parts and is electrical equipment. You are comparing apples with oranges by dragging the junction box distraction into the mix. There is no winning. In my town, 110.26 applies. In every town I worked for someone else, 110.26 applies.

 

[jar546]

I'm with ICE....unless we want to not allow switches over counters in the kitchen anymore.....But I am sick of stupid NEC stuff....

This comment is in left field.

 

[steveray]

A disconnect without OCPD is really nothing more than a switch....Switches don't get working clearance....Unless you want to apply all of 110.26 (depth, height, width, projections) to every switch, I like the OCPD "rule".....

 

[Paul Sweet]

They can always remove the access panel on the unit, which has adequate clearance if the unit was installed in accordance with the manufacturer's instructions. if they want to be lazy and just pull the popout they need to take protective measures on their own.

 

[BN4537]

I had always believed that 110.26 applied to AC disconnects. A disconnect is certainly a piece of electrical equipment. On further examination, it depends entirely on if the AHJ believes that a disconnect is likely to be worked on while it is live.

A friend of mine had an issue with their AC condenser and asked me to come look at it. I am not an HVAC guy. I went out and cycled the unit on and off a few times. The problem seemed to be electrical in nature - it turned out that it was the capacitor in the unit. I wanted to eliminate the possibility of any problems coming from the house wiring feeding the unit, so I opened the disconnect and tested the voltage. Everything tested fine, so I knew the problem was in the unit, and probably the capacitor. The home owner hired a licensed HVAC company, who did their own analysis and replaced the capacitor. This story mainly illustrates that sometimes the disconnect is the best place to test if you think something may be screwy with the house wiring to the AC unit.

An AC unit's case is bonded, so if you contact live parts while touching the case of the AC unit, you're gonna get nailed. Completely different than leaning over wood cabinets in a kitchen. If the disconnect is behind the unit, you might have to lay across the bonded metal to access the disconnect.

My opinion is that 110.26 applies, but the other interpretation is valid if it is made by the AHJ.

 

[steveray]

An AC unit's case is bonded, so if you contact live parts while touching the case of the AC unit, you're gonna get nailed. Completely different than leaning over wood cabinets in a kitchen. If the disconnect is behind the unit, you might have to lay across the bonded metal to access the disconnect.

My opinion is that 110.26 applies, but the other interpretation is valid if it is made by the AHJ.

But I have stainless counters in my kitchen....

 

[jar546]

A minor update.

I took this to our IAEI chapter meeting last night and was surprised that another inspector brought it for the same reason. If any of you don't know, the IAEI is not just inspectors but has a lot of electricians as members, actually more electricians than inspectors, so it represents both sides. Not one person agreed with the interpretation and was bewildered on how something that is so black and white could have been presented as having a gray area and misinterpreted. At first I thought we would have conflicting opinions from the electricians, but not at all. Oh for those that don't know IAIE is the International Association of Electrical Inspectors.

 

[steveray]

Maybe IAEI needs to get some people on a CMP and clarify it?

 

[ICE]

A minor update.

I took this to our IAEI chapter meeting last night and was surprised that another inspector brought it for the same reason. If any of you don't know, the IAEI is not just inspectors but has a lot of electricians as members, actually more electricians than inspectors, so it represents both sides. Not one person agreed with the interpretation and was bewildered on how something that is so black and white could have been presented as having a gray area and misinterpreted. At first I thought we would have conflicting opinions from the electricians, but not at all. Oh for those that don't know IAIE is the International Association of Electrical Inspectors.

I am not surprised that members of the IAEI meeting agree with you. There are a great many electricians and building officials/inspectors that agree with you. I know quite a few myself. I also know many that do not agree with you and they are no slouch.

I have lost a great deal of respect for the electrical industry as a whole. I see energized residential service panels left with the door open and the dead front removed waiting for an inspector to arrive. The work is often so wrong that I lose track of the violations.

I respect you Jeff and I count on a balanced, informed, fair opinion.
With this issue I would have no problem siding with you even If I disagree. That's me willing to admit that I can be wrong. Requiring working space is a step towards greater safety so it's easy to concede.

Back at it.​

Do you apply 110.26 to other disconnects or is it just condensers? For example, a furnace in a closet?...how about an electric water heater?

What is special about an AC condenser? I think that because many condenser disconnects are fused and they require working space, it has become common practice to require working space always. I understand the reluctance to reach over equipment to reach a disconnect. I use a non-contact voltage tester on anything metal before I touch it. The best approach is to assume that everything metal is trying to kill you and yet I never trip a breaker before opening a disconnect and removing the dead front.

This is from the BOAF informal interpretation:
The Building Officials Association of Florida, in cooperation with the Florida Building Commission, the
Florida Department of Community Affairs, ICC, and industry and professional experts offer this
interpretation of the Florida Building Code in the interest of consistency in their application statewide. This
interpretation is informal, non-binding and subject to acceptance and approval by the local building official.

It is noteworthy that four reputable organizations have come to an interpretation that conflicts with the vocal members of one IAEI chapter meeting. Also noteworthy is that you nor anyone else must pay heed to that interpretation. Do as you will and don't look back.

Food for thought: Section 440.14 has an informational note to see 110.26. Obviously there is something in 110.26 that can have a bearing on the condenser disconnect. However, that something is not ironclad because were it so there would not be just an informational note...no not at all. If 110.26 applied to every disconnect the body of 440.14 would include the requirement to adhere to 110.26.

 

[jar546]

Per the NFPA as of today based on this question, below is the answer.

Document Number: 70

Edition: 2017

Section: 110.26 and 440.14

Subject: The application of 110.26 to AC disconnects under 440.14

Question for NFPA: Does section 110.26 for working space requirements apply to A/C disconnects or are
they permitted to be readily accessible in the opinion of the inspector in lieu of compliance with 110.26?


Answer:
No. Section 110.26 is applicable to providing working space about all electrical equipment.

 

[jar546]

It is noteworthy that four reputable organizations have come to an interpretation that conflicts with the vocal members of one IAEI chapter meeting. Also noteworthy is that you nor anyone else must pay heed to that interpretation. Do as you will and don't look back.

FYI on that one. This is standard verbiage on non-binding decisions and as you know, the ICC has nothing to do with the contents of the NFPA which uses an extensive group of panels to make code changes. This was done with just a few people, only one of them was required to have any electrical experience. BOAF does not have separate panels for electrical, plumbing, mechanical, or structural, accessibility, etc. Just one person "should" have experience in this. The NFPA does not agree with this non-binding interpretation and neither does anyone else I spoke to. It's just void of common sense and tries to make something black and white appear to be gray when, in fact, it is not.

This is not one I will let go of. This is the hill I will die on.

 

[steveray]

Question for NFPA: Does section 110.26 for working space requirements apply to A/C disconnects or are
they permitted to be readily accessible in the opinion of the inspector in lieu of compliance with 110.26?


Answer:
No. Section 110.26 is applicable to providing working space about all electrical equipment.

Does anyone understand what this actually says or am I just hard of reading today?

 

[BN4537]

Does anyone understand what this actually says or am I just hard of reading today?

Sounds like the individual who answered did not properly read the question.

 

[jar546]

Sounds like the individual who answered did not properly read the question.

No, an ac disconnect that is readily accessible does not mean that 110.26 does not apply. In other words. All AC disconnects must meet 110.26

 

[chris kennedy]

As an electrician twisting tools in the field 6 days a week I'll share my view. On a trouble call I will start with the incoming power to the equipment.
Open disconnect and visually inspect (examine). Look for burnt lugs or conductors. Next check line and load voltage.

Thats this electricians opinion.

But what do I know? I'm just the guy who's body was found on a roof crammed between an RTU and non-compliant disco after his wife reported him missing when he didn't come home from work.

 

[jar546]

I will continue. I pay the NFPA for online code access and there are expandable sections of the code produced by the NFPA. Here is the expanded content of 110.26(A)

ENHANCED CONTENT
The intent is to provide enough space for the performance of any of the operations listed without jeopardizing workers. Minimum working clearances are not required if the equipment is not likely to require examination, adjustment, servicing, or maintenance while energized. However, access and working space are still required by the opening paragraph of 110.26.
Examples of such equipment include panelboards, switches, circuit breakers, controllers, and controls on heating and air-conditioning equipment. Note that the word “examination” includes tasks such as checking for the presence of voltage using a portable voltmeter.

 

[ICE]

But what do I know? I'm just the guy who's body was found on a roof crammed between an RTU and non-compliant disco after his wife reported him missing when he didn't come home from work.

That guy put himself in a situation where electricity could kill him. Apparently he didn't recognize the danger and that resulted in a deadly outcome.

When I hear about workplace mishaps I often wonder why the worker did what killed him. How did he not know that the trench was dangerous, the high voltage lines are too close......perhaps he shouldn't be using tools to begin with.

If the proximity of a disconnect is to be blamed for the injury/death of a workman there has to be a lack of skill, training or awareness. The incorrect disconnect is a lessor contributing factor.

The picture shows a violation. What is your judgement of the violation? Will moving the disconnect a foot improve the installation enough to justify the expense?





This condenser can't be where it is due to a setback incursion. The disconnect is also a violation.



How about these?




Here is a disconnect that is technically legal.

 

[steveray]

That guy put himself in a situation where electricity could kill him. Apparently he didn't recognize the danger and that resulted in a deadly outcome.

I wonder if he was following 70E?

 

[jar546]

All of those photos by ICE could have easily been installed correctly and compliant with NEC 110.26. The laziness to allow this to happen astounds me.