A Better Understanding of NFPA 70E: Electrical Equipment Working Space
The National Electrical Code® (NEC)® Section 110.26 requires adequate working space for all electrical equipment. NEC Section 110.26(A) requires a clear space at least 30 inches wide and 36 inches deep if the equipment is likely to be worked on while energized. This space is necessary not only to allow workers room to perform tasks but also room to move if something goes wrong. NFPA 70E®, Standard for Electrical Safety in the Workplace®, Section 110.3 requires that all equipment be placed into an electrically safe work condition (ESWC) unless there is proper justification for the equipment to be energized. NEC 110.26(A) still applies even if equipment will be in an ESWC.
The initial electrical inspection for a facility is conducted by a legislated authority having jurisdiction (AHJ). However, as with all NFPA 70E requirements, it is the employer who assigns someone as the AHJ within the facility. That person may also be the AHJ for the NEC requirements when new equipment is installed in that facility. Floor space is at a premium so providing larger working space is a common issue. An inhouse AHJ will try to convince the official AHJ that the equipment will never be worked on while energized. The problem with that argument is that both OSHA and NFPA 70E require equipment that is not in a verified ESWC to be considered energized. As far as the NEC is concerned, energized equipment requires working space no matter which AHJ inspects the installation.
The inhouse AHJ will claim that employee training, work procedures, equipment maintenance, and work practices assure that an employee will never work on the equipment energized. The inhouse AHJ may convince themselves that this is justification to use a working space smaller than NEC Section 110.26(A) when they are the sole AHJ. This argument typically fails when it is an official AHJ who must approve the proposed working space. They want to assure worker safety under any situation by providing the required space. Few official AHJs will approve a smaller working space based on conditions that are beyond their jurisdiction. They will not verify worker qualification, determine the effectiveness of the training program, check equipment maintenance records, or review work procedures and practices. Human error is a major contributor to workplace fatalities and injuries. An official AHJ will not want to sign off on an installation that will haunt them when a worker fails to follow the employer’s electrical safety program.
It takes experience to protect workers while preserving valuable floor space. Electrical safety is always affected by installation, maintenance, and work practices. There is equipment not likely to be worked on while energized. There are installation methods and techniques that can minimize the amount of working space required. There is equipment that operates below the minimum shock or arc-flash hazard levels. The full working space of NEC 110.26(A) will be necessary without a holistic approach to electrical safety. Make sure your installations provide the clear space necessary to keep a worker safe.
NFPA 70E and the NEC are now available in NFPA LiNK™, the association’s information delivery platform with NFPA codes and standards, supplementary content, and visual aids for building, electrical, and life safety professionals and practitioners. Learn more at nfpa.org/LiNK.