Topic: Code Enforcement

Electrical space: the final frontier where electrical inspectors voyage to explore two of the many requirements of section 110.26(A)

Electrical space: the final frontier. “These are the voyages of the electrical inspector.” This plays on a quote from one of my favorite Star Trek movies. Space, especially electrical equipment space in buildings, can seem like it is a final frontier because it is getting harder to come by. Or is it? Prior to the COVID outbreak, buildings were being built to house hundreds, even thousands of employees, so space for electrical and mechanical rooms was at a premium and in tight quarters. Office space, especially when being rented by the square foot, was made a higher priority. With the way that many of us work shifting due to the pandemic, designs of buildings are likely to also start shifting to accommodate the move to a more remote workforce, which occupies less space within buildings. This may cause office spaces to be consolidated, therefore giving more room for electrical and mechanical rooms. Consolidation of space for offices may be occurring, but the change in how we work appears aimed more at having open spaces being converted to conference rooms for team meetings. But no matter what is occurring in the space designated for offices or meeting rooms, the one area that cannot be compromised is the spaces about electrical equipment. There are two types of spaces around electrical equipment mentioned in the 2023 National Electrical Code® (NEC®): working space and dedicated equipment space. Each one has quite different requirements, but all aid in the safety of the worker and longevity of the installation. Working space within the NEC, in general, is comprised of three parts: Depth of Working Space - found in section 110.26(A)(1). This measurement factors in nominal voltage to ground and if there are grounded parts or exposed live parts across from the equipment. Measurements are taken from live exposed parts or from enclosure if live parts are enclosed, out the front until the minimum distance found in Table 110.26(A)(1) is met. Width of Working Space –in section 110.26(A)(2). This dimension is derived by measuring the width across the front of the equipment. This can be taken from center (15 inches in middle of equipment), from left side of equipment or from right side. No matter the voltage or amperage the width will never be less than 30 inches. Height of working Space – addressed in 110.26(A)(3). This is measured from grade, floor, or platform to a height of 6.5 feet and is the width of the equipment or minimally 30 inches. All these spaces combine to form a box, if you will, that is for the qualified worker to occupy when servicing or working on the equipment. This is intended to provide room to move, which is necessary to keep them from bumping into something and possibly getting shocked or causing an arc flash. This area also allows easy access to equipment should a breaker or disconnect need to be shut off quickly. Working space is not to be used for storage according to 110.26(B). In all my years as an inspector I can’t tell you how many times I have had to write that violation during the electrical inspections. These mostly occurred on remodels where circuits and wiring were added to the existing electrical systems. I would politely remind the building owner/occupant that working space was required to help keep the electrical worker safe from exposure to electrical hazards that may be present. New to the 2023 NEC in section 110.26(A)(6) is the requirement that the grade, floor or platform in the working space be clear and as level or flat as practical for the entire required depth and width. The dedicated equipment space in 110.26(E) is just what you would think it would be; space dedicated solely for the installation of electrical equipment. Indoor dedicated electrical space is found in 110.26(E)(1)(a), which electrical inspectors often refer to as the “thumb print” of the equipment plus six feet above the top of the equipment. For example, a panelboard 20-inches wide x 6-inches deep mounted to the surface of the wall at seven feet to the top would have dedicate electrical space extending up to 13 ft above the finished floor. So the overall dedicated space is 20-inches wide x 6-inches deep up to 13 ft. In general, only electrical items are allowed within that space, which might include: raceways (and associated fittings) wireways junction boxes This list is not all inclusive, but an idea of what may be seen within the vicinity of electrical equipment. One exception to the dedicated space requirement is made for suspended ceilings with removable panels. With design limitations imposed on room size, there may be the occasional foreign system intruding into the dedicated electrical space required by section 110.26(E)(1)(a), typically becoming a violation. So, if the system was installed in accordance with 110.26(E)(1)(b), which addresses foreign systems over the dedicated electrical space, there would not be a problem. Remember our example, the top of the dedicated electrical space was 13 feet above finished floor, so the foreign system would need to be higher than 13 feet. If a foreign system is subject to condensation or leaks, the electrical equipment would require protection from such occurrences, which may also mean the system needs to be higher since the method of protection is not allowed within the dedicated electrical space. This space was put into the code to ensure adequate access to the electrical system for the installation of associated parts and to protect the electrical installation from other systems foreign to the electrical system. Electrical space: the final frontier where the voyages of the electrical inspector have explored two of the many requirements of section 110.26(A). Find more information for electrical inspectors by visiting nfpa.org/electricalinspection. You can explore the 2023 NEC by purchasing a printed copy or have NFPA LiNK® beamed to your computer.

A Closer Look at Some Assembly Occupancy Requirements

The fire at a Thai nightclub in early August 2022 was all too familiar. It started during a live music performance killing 20 people and injuring 25. Many of the details emerging are eerily similar to The Station nightclub fire which claimed the lives of 100 people and injured 230 more in February of 2003. In both instances, flammable interior finish and blocked exits were believed to have played a role in the fast-spreading fires and high number of fatalities. The 2003 tragedy led to a number of changes to NFPA 101, Life Safety Code, while also reiterating the importance of interior finish and means of egress requirements for assembly occupancies. Interior finishes are the interior surfaces of a building that are generally secured in place like wall and ceiling coverings. They have proven to be a contributing factor in how quickly a fire spreads. To minimize the impact interior finish has on fire spread, Chapter 10 of the 2021 edition NFPA 101, Life Safety Code®, establishes basic requirements for interior wall, ceiling, and floor finishes. Chapter 10 outlines two testing options: 1) testing in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth; or 2) testing in accordance with ASTM E84 or UL 723.  Paragraph 10.2.3.1.2 of the 2021 edition of NFPA 101, outlines acceptance criteria for materials tested in accordance with NFPA 286. The acceptance criteria includes: limitations on the spread of flames; peak heat release rate less than 800 kW; and for new installations the total smoke released throughout the test cannot exceed 1000 m2. Any material that meets the criteria outlined in 10.2.3.1.2 can be used wherever a Class A material is permitted. The alternative test method (ASTM E84 or UL 723) results in the material being grouped into a class. There are three classes- Class A, Class B, and Class C which are determined by a material’s flame spread index and smoke developed index. Class A materials will have the lowest flame spread index of the three classifications. The smoke developed index is the same range for all three classifications. For newly installed materials both the flame spread index and smoke developed index is considered, whereas for existing materials only flame spread index is considered. Occupancy chapters may further regulate interior finish beyond what is contained in Chapter 10. In both fires, acoustic material is believed to have been a major contributing factor in the rapid spread of fire. Assembly occupancies do further regulate interior finish. The requirements are the same for new and existing assembly occupancies. In general assembly areas with an occupant load of 300 or fewer, ceiling and wall materials must be Class A, B, or C. In general assembly areas with an occupant load of more than 300, and in corridors, and lobbies, interior wall and ceiling finishes must be Class A or B. In enclosed stairs interior finish materials must be Class A. One other contributing factor was the availability of exits. In both the fire in Thailand and at The Station nightclub, one of the doors to the outside was blocked for use by occupants to allow the band performing to have their own separate entrance/exit. One of the fundamental components of the Life Safety Code is the concept of free egress. Prohibiting people from entering the building via a door is one thing, but not allowing occupants to exit the building via the nearest door is unacceptable. Additionally, NFPA 101 prohibits the means of egress for assembly occupancies from going through hazardous areas such as kitchens, storerooms, closets, stages, and platforms. There are also requirements related to the size of a main entrance/exit, where one exists. History has shown that occupants tend to go out the way they came, even if there is an exit closer. The main entrance/exit provisions are intended to prevent crowd crush situations. In existing assembly occupancies, the main entrance/exit needs to be sized to accommodate at least one-half the total occupant load. For new assembly occupancies that are dance halls, discotheques, nightclubs, or that have festival seating, the main entrance/exits must be wide enough to accommodate two-thirds of the total occupant load. The main entrance/exit for all other new assembly occupancies must be sized to accommodate one-half the total occupant load. If the assembly occupancy is more than one level, then each level must have access to the main entrance/exit and that access must be sized to handle two-thirds (for new assembly occupancies) or one-half (for existing) of the occupant load of that level. The main entrance/exit requirements for certain types of new assembly occupancies was increased from one-half to two-thirds the total occupant load due to a crowd crush event during The Station nightclub fire. Another way the Life Safety Code strives to reduce the risk of crowd crush is by requiring trained crowd managers. All assembly occupancies, with the exception of certain ones used exclusively for religious worship, are required to have at least one trained crowd manager. Depending on the total occupant load, additional crowd managers may be required. Typically, there should be one crowd manager for every 250 occupants. Prior to the 2006 Edition, crowd managers were only required for assembly occupancies with occupant loads of more than 1000. After The Station nightclub fire, the Life Safety Code was changed to require at least one crowd manager for all assembly occupancies. Within 2 minutes of the fire starting at The Station nightclub, there was crowd crush at the main entrance/exit. This led to the main entrance/exit being almost completely impassable. The crowd manager’s responsibilities include understanding crowd management, understanding methods of evacuation, being familiar with the facility evacuation plan, being familiar with the emergency response procedures, and understanding procedures for reporting emergencies. While the cause of the recent fire at the Thai nightclub is still under investigation, The Station nightclub fire was caused by pyrotechnics. To reduce the risk of open flames or pyrotechnics starting a fire in an assembly occupancy they are prohibited unless certain conditions are met. In order for pyrotechnics to be used on stage before proximate audiences, precautions to prevent ignition of any combustible material, satisfactory to the authority having jurisdiction must be met and the use of the pyrotechnic device must comply with NFPA 1126, Standard for the Use of Pyrotechnics Before a Proximate Audience. As we have seen countless times, fires in assembly occupancies, and in particular nightclubs, can result in a high number of fatalities. By carefully considering the use of open flames and pyrotechnics we can eliminate potential ignition sources in these types of occupancies. Additionally, ensuring the interior finish requirements for assembly occupancies are met can help slow the spread of fire. Fires in an assembly occupancy have the added risk of leading to a crowd crush event. Compliance with the means of egress and crowd manager requirements will help reduce the risk of crowd crush events during emergency situations. 

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 6 - Inspections)

NFPA 70E®, Standard for Electrical Safety in the Workplace® has requirements for what should be included in an electrical safety program (ESP) but does not provide details. The requirement in Section 110.5(B) to inspect electrical equipment is one where it is the employer’s responsibility to fill in the gaps. A properly documented ESP does not exist until that has been accomplished. The policies and procedures in your ESP are what employees must be trained to follow. The ESP must address the inspection of newly installed or modified equipment. Does your ESP have a way to assign this responsibility? A newly hired, residential electrician may not be the appropriate inspector for a smelting facility. The local electrical inspector often does not inspect equipment that falls under NFPA 70E. Equipment is installed, maintained, repaired, and replaced by an employee or an outside contractor. The responsible person will need to not only determine that an installation meets the applicable manufacturer requirements but also those of applicable standards. This is not limited to electrical standards since things like improperly installed pressure systems in electrical equipment may affect safety. What are the ESP policies and procedures for these inspections? An ESP that requires that equipment be verified as complying with the NEC is not enough. Electrical system and equipment compliance with the NEC is often only determined during building construction. The NEC does not address maintenance nor is internal electrical circuits part of the NEC. However, technicians maintaining motor control equipment must know the applicable NEC requirements. A contracted HVAC technician may be required to provide documentation that their work complies with applicable standards and codes, as well as the facilities requirements. Is their work inspected by a facility employee? Who is authorized to inspect repairs on custom production line equipment? It might not be desirable for the employee performing the work to also perform the inspection. The ESP must address not only these issues but also the training of the employee conducting inspections. The ESP might permit some types of electrical work to be completed without additional inspection. Do employees know which specific equipment is permitted to be energized before or without the additional inspection? A contractor may not follow the same safety protocol. Perhaps, it is not the equipment but the task that directs an inspection before energization. The ESP must address how to document all of this and what is to happen with the results. A requirement for the inspector to evaluate alternate installation methods may provide a means to mitigate hazards or repeated exposures. However, this most likely will not happen without a statement to do so in the ESP.  Proper installation, repair, and modification of electrical equipment play a major role in protecting every employee from electrical hazards. Inspection to determine that fact is a requirement in NFPA 70E. NFPA 70E is a safe work practice standard that is not appropriate to be used as the procedure for equipment inspection. It is critical to train an employee on inspection policies and procedures contained in the documented ESP.
Man looking at tablet and working with a piping system

Weekly or Monthly No Flow (Churn) Tests of Fire Pumps

Fire pumps are an essential part of many water-based fire protection systems. They are used to increase the pressure (measured in psi or bar) of a water source when that source pressure is not adequate for the system it’s supplying. The right design, installation, and acceptance testing of these pumps will ensure that they are ready and available to protect the building on the day of the acceptance test. After that, once “the keys” are handed over to the building owner, there is no guarantee that the pump will remain in a ready state to work as designed unless it undergoes routine inspection, testing, and maintenance (ITM). The requirements for ITM of fire pumps are found in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. &nbspWhile there is a good deal that goes into a robust ITM program for fire pumps, this blog will focus on the no-flow test of fire pumps which is often referred to as a churn test. See this blog for weekly fire pump inspections. What is the purpose of the no-flow test? NFPA LiNK where hot spots can be chosen to find more information about certain inspection and testing requirements for different components. How often is a no-flow test required? The no-flow (churn) test of fire pumps must be conducted at either a weekly or monthly basis. The frequency varies by the type of fire pump; diesel and electric; and both have allowances to extend the time between tests based on approved risk analysis.  Generally, diesel fire pumps must be no-flow (churn) tested on a weekly basis. The requirements for electric fire pumps vary. Most electric fire pumps can be no-flow (churn) tested at a monthly frequency. Electric fire pumps which (1) serve fire protection systems in buildings that are beyond the pumping capacity of the fire department, (2) have limited service controllers, (3) are vertical turbine fire pumps, or (4) those taking suction from ground level tanks or a water source that does not provide sufficient pressure to be of material value without the pump all require no-flow (churn) tests at a weekly frequency unless they are provided with a redundant fire pump. Starting The no-flow (churn) test needs to be conducted by starting the pump automatically. The pump must be started by drawing water from the sensing line to simulate a pressure drop in the system rather than using the “start” button on the front panel of the fire pump controller. An allowance is included in NFPA 25 for an automatic timer using either a solenoid valve drain on the pressure control line for a pressure-actuated controller or another means for a non-pressure-actuated controllers. Run time Electric pumps must be run for a minimum of 10 minutes while diesel pumps must be run for a minimum of 30 minutes. Personnel  Qualified personnel must be in attendance whenever the pump is in operation unless automated inspection and testing is performed in accordance with the requirements of NFPA 25. Check out this blog for more on automated and remote inspection and testing. Qualified personnel is defined in NFPA 25 as competent and capable individual(s) having met the requirements and training for a given field acceptable to the AHJ.  Relief valves NFPA 25 allows the circulation relief valve to open to flow water as a cooling measure. Allowing any additional water flow to prevent overheating is not a requirement of the standard. Flow from the circulation relief valve should be sufficient to prevent over-heating of the pump. It should be confirmed that the circulation relief valve is discharging a small flow of water during the no-flow (churn) test. There are additional details around circulation relief valves and main pressure relief valves in NFPA 25 which personnel should familiarize themselves with. Visual observations while pump is not running The following visual observations need to be conducted while the pump is not running. Record the system suction and discharge pressure gauge readings. For pumps that use electronic pressure sensors to control the fire pump operation, record the highest and lowest pressure shown on the fire pump controller event log where such information is available without having to open and energized motor-driven fire pump controller. If the highest or lowest pressure is outside of the expected range, record all information from the event log that helps identify the abnormality. Visual observations or adjustments while pump is running The following visual observations or adjustments need to be conducted while the pump is running. Pump system procedure as follows: Record the pump starting pressure from the pressure switch or pressure transducer Record the system suction and discharge pressure gauge readings Adjust gland nuts if necessary Inspect the pump packing glands for slight discharge Inspect for unusual noise or vibration Inspect packing boxes, bearings, or pump casing for overheating Record pressure switch or pressure transducer reading and compare to the pump discharge gauge For pumps that use electronic pressure sensors to control the fire pump operation, record the current pressure and the highest and the lowest pressure shown on the fire pump controller event log. For electric motor and radiator cooled diesel pumps, check the circulation relief valve for operation to discharge water Electrical system procedure as follows: Observe the time for motor to accelerate to full speed Record the time controller is on first step (for reduced voltage or reduced current starting) Record the time pump runs after starting (for automatic stop controllers) Diesel Engine system procedure as follows: Observe the time for engine to crank Observe the time for engine to reach running speed Observe the engine oil pressure gauge, speed indicator, water, and oil temperature indicators periodically while engine is running Record any abnormalities Inspect the heat exchanger for cooling waterflow Steam system procedure as follows: Record the steam pressure gauge reading Observe the time for turbine to reach running speed In addition to the above, the discharge temperature of the water must be monitored, and the pump shut down if necessary to prevent exposing the pump and/or driver to excessive temperatures. Where the recorded pressure readings on the discharge and suctions gauges show a difference that is greater than 95 percent of the rated pump pressure, the situation needs to be investigated and corrected. The weekly or monthly no-flow (churn) test is an important part of ensuring that a fire pump can be continually relied upon in the event of a fire. These tests will help to ensure that the pump will start and will not overheat in the event of a fire. At an annual frequency, flow testing will be performed to further verify the complete operating condition of the pump. NFPA has a number of resources related to fire pumps and the ITM required for them. Some of these include NFPA 20 Online Training Series, NFPA 25 Online Training Series, the NFPA 25 Handbook, the Certified Water-Based Systems Professional (CWBSP) credential, and the Certified Water-Based Systems Professional Learning Path among many others.
Man inspecting and looking at a tablet

Automated and Remote Inspection and Testing of Water-Based Fire Protection Systems

Remote inspections and automated testing were trends that were gaining momentum in codes and standards and field application for several years. Then in the first half of 2020 when the COVID-19 pandemic was in its early stages and strict lockdowns were being enforced, it pushed this trend to progress even faster as many more realized its potential. During this time, the development of a proposed new standard NFPA 915, Standard on Remote Inspections, continued. While the proposed NFPA 915 will be broadly applicable to any inspection or testing allowed by the AHJ, there are already provisions in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, that allow for inspections and tests to be conducted in an automated manner. Automated inspection and testing can be a very useful option but what steps must be taken to ensure it is equivalent to a person being at the location? If a fire pump demonstrates an abnormal condition during a test what must the response be and how is the condition corrected? Let’s take a look at the requirements in NFPA 25 to allow the use of technology for automated inspection and testing and the criteria to ensure it meets the same objectives as when they are conducted in person. The first thing to address is when and where automated inspection and testing can be utilized. NFPA 25 does not limit the use provided automated inspection equipment can meet the intent of a required visual inspection and automated testing equipment can produce the same action as required by the testing requirements. Beyond that there are a few other criteria specific to when automated inspection and testing is utilized such as where automated tests do not discharge water that at least once every 3 years the discharge must be visually observed. At that point it becomes a cost-benefit analysis for the stakeholders and primarily the building owner. Activities required at greater frequencies might present more of a benefit while those required less frequently might see less of a benefit. Let’s review the requirements specific to automated and remote inspections. To start, automated test devices must be listed for the purpose of the test being conducted if they are subjected to system pressure or are integral to the operation of the system during a fire event. The equipment must be such that its failure does not impair the operation of the system unless that failure can be indicated by a supervisory signal to the fire alarm system. Similarly, any failure of a component or system to pass an automated test must result in an audible supervisory signal and failure of automated inspection and testing equipment must result in a trouble signal. The monitoring and signals required ensure that instances where there are issues with the automated testing or inspection equipment or an unsatisfactory inspection or test result notification will be made and the situation can be remedied. The testing frequencies of NFPA 25 must be maintained regardless of the functionality of automated testing equipment and a record of all inspection and testing must be maintained in accordance with the requirements that apply to all inspection and testing. One of the benefits of automated inspection and testing is that there is not necessarily a need for personnel on site. However, certain circumstances might need to be addressed quickly. This is specified for no-flow testing of fire pumps. This testing is required on a weekly or monthly basis depending on the type of pump and the building it is located in.  The 2020 edition of NFPA 25 requires that when remotely monitored automated testing of the no-flow fire pump test is being performed qualified personnel must be able to respond to an abnormal condition within 5 minutes. In all reality, this means that a qualified person must be located on site. For the proposed 2023 edition which will be approved this summer that timeframe is to be changed to 4 hours. This additional time means that someone does not need to be immediately on site but can respond quickly enough to take the needed corrective action. The use of technologies to perform automated inspections and testing will only grow in future years. As it becomes more widely used, as building owners, service providers, and AHJs gain more experience, and the use expands into other areas of fire protection and life safety with the future publication of NFPA 915, it is very likely that the requirements will continue evolve
Person on a tightrope

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 5 – Risk Assessments)

NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(H) requires that a risk assessment procedure be developed as part of an electrical safety program (ESP). NFPA 70E is not a how-to manual for detailing a risk assessment procedure. It is also not appropriate for training an employee how to conduct the assessment. There are hundreds of valid methods of performing risk assessments for the thousands of tasks that could be conducted on the millions of pieces of equipment available. Section 110.5(H) requires a minimum of three things to be addressed and documented before any employee begins a task. The risk assessment procedure must detail the process that will be used to: identify hazards assess risks implement the hierarchy of risk controls Consistency is important when conducting risk assessments. Without it an employee conducting an assessment may tolerate a risk level that is not acceptable, ignore hazards that have been previously recognized, or improperly apply the hierarchy of risk controls. Training an employee to follow NFPA 70E Section 110.5(H) rather than your documented procedure will introduce such unsafe practices. Identify Hazards – NFPA 70E defines an electrical hazard as a dangerous condition such that contact or equipment failure can result in electric shock, arc flash burn, thermal burn, or arc blast injury. The two hazards (shock and arc-flash) currently covered by NFPA 70E are easily recognizable. The potential for an electrical shock typically at starts at 50 volts. An arc-flash burn begins at 1.2 cal/cm2. Contact burns can occur at temperatures as low as 44°C (110°F) if the contact is prolonged and as quick as a second above 80°C (186°F).  There currently is no consensus on what an arc-blast hazard is. NFPA 70E does not specify where any of these hazards exist. It is the role of the ESP to cover how equipment is evaluated to determine if these hazards are present during any task performed on equipment. Assess Risks - Human factors are generally recognized as being among the leading causes of injury and the potential for human error must be addressed in a risk assessment. This takes knowledge not only of the assigned task but also the location of the task, the equipment to be worked on, the tools to be used, competency of the employee assigned, and other issues. Working above a piece of equipment provides an opportunity for items to be dropped into ventilation openings or for an employee to choose to stand on the lower equipment rather than use an appropriate platform. Maybe an employee could confuse a Category I meter for a Category III meter because of a similar design. The risk assessment procedure should address what is to be considered a potential human error when conducting the specific task on the equipment in its installed location. Implement the Hierarchy of Risk Controls - The hierarchy of risk controls must also be addressed. It is beneficial to include a requirement for a risk assessment prior to purchasing or installing equipment to achieve the maximum benefit of the hierarchy. For installed equipment, requiring the assessment to retroactively apply the hierarchy to mitigate risks before the same task is performed again can increase workplace safety. The risk assessment procedure must require that elimination be the first control considered when planning a task. It must address why elimination was not used or required before applying other controls including personal protective equipment (PPE). Not having a documented procedure for conducting risk assessments is dangerous. Acceptable and unacceptable risks will vary. Electrical hazards will not be properly addressed. The use of PPE as the sole means of protecting employees will become commonplace. Inconsistency in risk assessments could put an employee at a higher risk of injury when conducting the same task on different equipment. Make sure a documented risk assessment procedure is part of your ESP and is used for every risk assessment.
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