You've correctly identified the issue and the seemingly strict interpretation of 240.24(B) in the 2023 NEC. It's a challenging and sometimes confusing section, and your assessment of its implications is accurate. Let's break down why this is tricky and how it's often practically addressed (or arguably, ignored).

Understanding the Intent

The core intent of 240.24(B) is safety. It's designed to ensure that occupants can quickly and easily shut off power to circuits within their occupancy in case of an emergency (e.g., a fire, short circuit). It also allows occupants to restore power to a circuit they tripped themselves, assuming they understand why it tripped.

Why It Feels Wrong in Many Commercial Applications

You're right to point out that the strict interpretation of 240.24(B) clashes with common practices in many commercial settings. Here's why:

Shared Electrical Rooms

Commercial office buildings often have shared electrical rooms serving multiple tenants. Giving each tenant unrestricted access to that room means giving them access to the OCPDs for other tenants, which creates security risks, potential tampering, and safety concerns.

Specialized Equipment

Many commercial spaces have specialized equipment that should only be serviced by qualified personnel. Giving general access to the OCPDs could lead to accidental shutdowns or improper handling.

Liability

Building owners and managers are often concerned about liability if tenants improperly operate or tamper with electrical equipment.

Management Responsibility

Building management often prefers to retain control over electrical systems for efficient maintenance and troubleshooting.

How It's Often Handled (and Potential Justifications)

Here's where things get less clear-cut and potentially subject to interpretation by the Authority Having Jurisdiction (AHJ). There is no substitute for consulting with your AHJ during the design process.1.

The "Continuous Building Management Supervision" Argument (Stretching the Exception)

You mentioned this as an option and it's a weak argument outside of guest rooms and dorms. 240.24(B)(2) specifically addresses guest rooms, guest suites, or sleeping rooms in dormitory units. While some might try to argue that "continuous building management supervision" allows for restricted access in other commercial spaces, this is not clearly supported by the text. The AHJ would likely reject this, and rightly so. This exception is for hotels and dorms.2.

Tenant Panels Within the Occupancy

The most legitimate and common approach is to install a tenant panel within each tenant's leased space. This panel would be fed from a feeder in the common electrical room, and all branch circuits for that tenant's occupancy would originate from this panel. The tenant then has ready access to their OCPDs without accessing the common electrical room. This approach is code compliant because the occupants have access to the OCPDs that provide overcurrent protection to the conductors supplying their occupancy.3.

Dedicated Electrical Rooms per Tenant

A second option is to have dedicated electrical rooms for each tenant. This is not a common practice, but it is code compliant since the OCPDs in the room provide overcurrent protection to the conductors supplying that tenant's occupancy.4.

AHJ Approvals and Project Exceptions

It is possible that an AHJ could grant an exception to this code depending on the building type and purpose.

Important Considerations and Best Practices



Communication with the AHJ is Crucial

Before finalizing any design that deviates from a strict interpretation of 240.24(B), discuss your approach with the local AHJ. Get their feedback and approval in writing. They have the final say.

Tenant Panels are Generally the Best Solution

Prioritize tenant panels within each occupancy. This offers the best balance of code compliance, tenant convenience, and building management control.

Clear Labeling

Ensure all panels and circuits are clearly and accurately labeled. This is essential for safety and troubleshooting, regardless of access restrictions.

Training

If building management is responsible for resetting breakers for tenants, provide adequate training to those personnel.

Consider Emergency Disconnects

In some applications (especially industrial), consider adding clearly marked emergency disconnect switches that can quickly shut off power to specific areas or equipment.

Remote Breaker Reset New technologies offer remote breaker resets through a building management system. This offers a cost effective, safe solution for situations that occur during business hours.

In summary: You're not wrong in your understanding of the code. It's a problematic section in commercial applications. The best approach is to design with tenant panels within each occupancy, communicate with the AHJ, and prioritize safety in your design. Flag for review