ECN Forum Forums General Topics of the Trade General Discussion Area Disconnecting Means

Here's a good discussion: I will invite the writer to join in here: My answer is "NO" and that the lock on any panel does not give us a disconnecting means that can be locked off.
That's one of the reasons why the word "individually" was added below:

430-102(b) Motor. A disconnecting means shall be located in sight from the motor location and the driven machinery location.

Exception: A disconnecting means, in addition to the controller disconnecting means as required in accordance with Section 430-102(a), shall not be required for the motor where the disconnecting means for the controller is individually capable of being locked in the open position.

Here's the message and question:

"Joe
I was reading the Code Catastrophe section (EC&m, page 60, April) and came
across the violation concerning the requirement for a disconnect switch for
the water heater. It would appear that this section, NEC 422-31(b), would
also apply to home dishwashers, built-in ovens and stoves, whole house fans,
etc. I have never seen a disconnect used on one of these appliances and
wonder if the locking system provided on the door of the panel board feeding
these devices can be considered the locking means? In particular a flush
mounted panel with a lock built into the door or a surface mounted panel
with a provision to apply a padlock."

PS: I sent in a proposal to cover this issue and here is waht the Code Panel had to say about this request:

(Log #2772)
20- 10 - (422-31(b)): Reject
SUBMITTER: Joseph A. Tedesco, Nat'l Technology Transfer, Inc.
RECOMMENDATION: Add the word “individually” in between the
words “being” and “locked.”
SUBSTANTIATION: This word will help to avoid the questions as
to whether or not a panel cover hasp, and lock or other locking
device constitutes a disconnecting means.
PANEL ACTION: Reject.
PANEL STATEMENT: The submitter has not provided sufficient
substantiation for the need for this proposal.
NUMBER OF PANEL MEMBERS ELIGIBLE TO VOTE: 12
VOTE ON PANEL ACTION:
AFFIRMATIVE: 11
NOT RETURNED: 1 Ryan

Here is the only comment made by the Chairman of CMP 10:

___________________
(Log #1928)
20- 7 - (422-31(b)): Reject
SUBMITTER: James T. Dollard, Jr. , Philadelphia, PA
COMMENT ON PROPOSAL NO: 20-10
RECOMMENDATION: Accept this proposal in Principle as
follows:
422-31. Disconnection of Permanently Connected Appliances
(a) Rated at Not Over 300 Volt-Amperes or 1/8 Horsepower. For
permanently connected appliances rated at not over 300 volt-amperes
or 1/8 hp, the branch-circuit overcurrent device shall be
permitted to serve as the disconnecting means.
(b) Appliances Rated Over 300 Volt-Amperes or 1/8 Horsepower.
For permanently connected appliances rated over 300 volt-amperes
or 1/8 hp, the branch-circuit switch or circuit breaker shall be
permitted to serve as the disconnecting means where the switch or
circuit breaker is within sight from the appliance or is capable of
being locked in the open position. The provision for locking or
adding a lock to the disconnecting means shall be permanently
installed on or at the switch or circuit breaker used as the
disconnecting means.
FPN No. 1: For motor-driven appliances of more than 1/8 hp, see
Section 422-35.
FPN No. 2: For appliances employing unit switches, see Section
422-33.
SUBSTANTIATION: This safety driven proposal should be
accepted in principle. The intent of the submitter is similar to the
intent of proposal 11-70 in this cycle to section 430-102(b)
Exception. Proposal 11-70 was Accepted in Principle and the Panel
action is reflected word for word in the proposed recommendation
above to section 422-31(b).
The present text of 422-31(b), which reads as follows "…where
the switch or circuit breaker is within sight from the appliance or is
capable of being locked in the open position." Clearly requires that
the switch or circuit breaker be CAPABLE of being locked in the
open position.
The problem with the present wording of this section is that the
disconnect in many appliance installations is a circuit breaker in a
panelboard or a snap switch, neither of which have permanent
provisions for being locked in the open position. This clearly does
not meet the requirements of 422-31(b). The present text of 422-
31(b) which reads as follows "…where the switch or circuit breaker
is within sight from the appliance or is capable of being locked in
the open position." clearly requires that the switch or circuit
breaker be CAPABLE of being locked in the open position. The
intent of this section is that with lock in hand an
installer/maintainer can apply the lock and work safely. This text
in the NEC does not include "through the use of a device which
will permit a lock to be utilized".
However the onset of circuit breaker locking devices have given
the impression that any circuit breaker is capable of being locked
in the open position.
OSHA does not permit circuit breaker lockout devices.
OSHA requires that they be approved (listed by a Nationally
Recognized Testing Laboratory). None are listed. Even if these
devices were listed for the purpose then the NEC would expect that installers/maintainers would each carry dozens of different
accessory devices to safely lockout power sources. This is not
practical.
Permanent provisions for making a circuit breaker and/or snap
switch capable of being locked in the open position are readily
available from manufacturers today.
Proposal 20-10 and this comment will not represent a large
increase in the cost of an installation but will result in a dramatic
increase in safety.
The practical safeguarding of persons from electrical hazards as
detailed in the scope of the NEC must not be permitted to hinge
on whether or not an installer just happens to have an accessory
device that just happens to fit a snap switch or circuit breaker in a
given installation.
Where permanently connected appliances rated over 300 volt-amperes
or 1/8 hp, are installed we know that regular maintenance
will take place, we must ensure that only a lock is needed by an
installer/maintainer to work safely.
PANEL ACTION: Reject.
PANEL STATEMENT: The submitter did not provide sufficient
technical substantiation for the original proposal to require
individual requirements for locking.
NUMBER OF PANEL MEMBERS ELIGIBLE TO VOTE: 12
VOTE ON PANEL ACTION:
AFFIRMATIVE: 12



[This message has been edited by Joe Tedesco (edited 04-25-2001).]

Joe,
so lemme get this straight, "individually" was put in 430 to discontinue panel door locks.
this would still apply to 422, as 'individually' did not make it, according to the rejected rop's.

however, most of those appliances are on individual circuits right?

Washington state AHJs require locking out the water heater's branch circuit breakers.
They want to see a locking device in the service panel at the time of inspection.

What is meant by this ? I do not understand.


However the onset of circuit breaker locking devices have given
the impression that any circuit breaker is capable of being locked
in the open position.
OSHA does not permit circuit breaker lockout devices.
OSHA requires that they be approved (listed by a Nationally
Recognized Testing Laboratory). None are listed.

Sparky,
I think that he is referring to the locking devices that are not a permanent part of the panelboard.
Don(resqcapt19)

So all my LOTO is NFG according to OSHA ? I thought i was to carry/use it to comply?

Sparky,

Take a look at this OSHA Standards Interpretation and Compliance Letter about generic circuit breaker lockout devices http://www.osha-slc.gov/OshDoc/Interp_data/I20000628.html

The LOTO regulation for general industry can be found here: http://www.osha-slc.gov/OshStd_data/1910_0147.html

I only know a little about OSHA regulations, maybe they have more stringent requirements for construction or electrical trades. After reading this, it seems to me that generic adapters to lock circuit breakers used for LOTO do not need to be 'approved.' Read the letter and 29 CFR 1910.147(c)(5)(i-iii) and see what you think.

Phil H

[This message has been edited by Phil H (edited 04-27-2001).]

Well thanks for the info & links guys, but I think i'm fairly confused here.

I can remeber the art 430 panel door lock change, had to address the individual breaker.

Now Joe's thread here would like to see the same for 422...


But the LOTO i carry, which includes breaker lockouts that are generic, because we'd all like to carry a tool good for most breakers, is NFG according to OSHA.

Apparently, there must be some force included to qualify these LOTO's, as they (per letter) tend to fall off easy.

Sounds like the panel door lock's looking better to me!