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Topic: 36" space in front (mobile enclosure)

User: Mike Clarquist, Location: Wisconsin

Asked on: Monday, February 10, 2025 at 12:10 pm EST
Answered on: Thursday, March 6, 2025 at 8:27 am EST

Question: Hello. We have several pieces of equipment that are mobile and easy to move. Sometimes the electrical panels that house the I/O, contactors, power, CB's etc... are up against a wall. If service is needed the system is on wheels and can be moved or pivoted to get the proper clearance. These systems are all corded, with 240VAC wall plugs...not disconnects or permanent power is attached. Is it okay to be able to move them when needing service to get the required 36" x 30" space or is that required at all times?

This is a common and important question. Here's a breakdown of the relevant NEC (National Electrical Code) considerations and how they apply to your situation, plus some best practices

NEC Requirements and Interpretations

The key section of the NEC you're concerned with is 110.26 - Spaces About Electrical Equipment. This section mandates working space around electrical equipment operating at 600 volts, nominal, or less, and likely applies to your 240VAC systems.Here's a summary: 110.26(A) Working Space

This is the core requirement.


Depth

The depth of the working space (the distance you need to stand in front of the equipment) is determined by the voltage and the conditions on the opposite side of the working space (e.g., grounded surface, live parts on the opposite side, etc.). Your 240VAC likely falls into Condition 1 or 2, requiring 3 feet or 3.5 feet, respectively.

Width

The width of the working space must be the
width of the equipment or 30 inches, whichever is greater. The working space must be clear and extend from the floor to the height of the equipment or 6.5 feet, whichever is greater.

Height

The working space must be clear and extend from the grade, floor, or platform to the height specified in 110.26(E). In general, the height is 6 1/2 feet.

110.26(B) Clear Spaces

Working space required by 110.26 cannot be used for storage.


110.26(C) Entrance to Working Space

Adequate access and egress are required.

110.26(D) Illumination

Adequate lighting is required.


110.26(E) Headroom

Sufficient headroom is required, typically 6.5 feet or the height of the equipment if higher.

The "Moveable Equipment" Exception – A Gray Area


The NEC doesn't explicitly address equipment that can be moved to provide working space. This creates a gray area, and the interpretation often comes down to the authority having jurisdiction (AHJ), which is typically the local electrical inspector.Here's a breakdown of arguments for and against allowing the movement of equipment to provide working space: Arguments against allowing movement



Intent of the Code

The NEC is designed to ensure safety at all times, not just when you're actively working on the equipment. If the equipment is typically against a wall, the argument is that a potential hazard exists until the equipment is moved.

Accessibility for Emergency Situations

In an emergency (e.g., an electrical fire or short circuit), quick access to the panel is crucial. Having to move equipment first could delay critical response time.


Unpredictability

Relying on moving equipment assumes that it will be moved correctly and safely every time. There's a risk that someone might attempt to work on it without moving it or might not move it far enough.

Arguments
for allowing movement (with caveats)



Equivalency to a Disconnect

Some AHJs might be more lenient if unplugging the equipment is considered equivalent to a disconnect, rendering the panel de-energized and safe to work on without the full working space. However, this is highly dependent on the specific situation and the AHJ's interpretation. You'd need to demonstrate that unplugging the equipment truly makes it safe to work on (e.g., no stored energy in capacitors).

Controlled Access

If you have strict procedures and training in place to ensure the equipment is always moved correctly
before any work is performed, and that only qualified personnel are permitted to perform such tasks, the AHJ might be more willing to consider it. Documentation is key.

Key Considerations and Recommendations
1. Consult with Your AHJ

This is the
most important step. Contact your local electrical inspector and discuss your specific situation. Get their interpretation of the NEC and their acceptance (or rejection) of your proposed solution in writing. What works in one jurisdiction might not work in another.2.

Engineering Justification

Prepare a detailed explanation of why you believe your approach is safe and meets the intent of the NEC. Include:
A description of the equipment and its electrical components. The procedures for moving the equipment (e.g., clear instructions, required tools, training). The level of training required for personnel who will be working on the equipment. The methods for ensuring the equipment is properly de-energized before any work is performed. Drawings or diagrams showing the working space that will be available after the equipment is moved.3.

Safety Procedures and Training

Develop and implement comprehensive safety procedures that cover: Lockout/Tagout (LOTO) procedures for de-energizing the equipment. Proper use of personal protective equipment (PPE). Detailed instructions for moving the equipment safely. Training records for all personnel who will be working on the equipment.4.

Signage

Clearly label the equipment with instructions on how to move it and the required working space.5.

Alternative Solutions (Consider These)



Relocate the Panels

If possible, the best solution is to move the electrical panels to a location where they will always have the required working space.


Modify the Equipment Layout

Consider redesigning the equipment layout so that the panels are more accessible.

Use Flexible Conduit

If the panels are close to the wall, use flexible conduit to allow them to be pulled away from the wall for servicing without completely disconnecting them. Ensure the flexible conduit is properly sized and supported.


External Disconnects

Adding an external disconnect that is easily accessible can mitigate some concerns, as long as it is installed properly and meets code requirements. This would need to be installed by a licensed electrician and inspected.

In Summary:


While your "movable equipment" approach isn't explicitly prohibited by the NEC, it's a gray area that requires careful consideration and approval from your AHJ. Proactive communication, a well-documented justification, and robust safety procedures are essential. Consider alternative solutions that provide permanent working space to eliminate the ambiguity and ensure compliance with the NEC. Don't risk safety or potential fines – get it right the first time. Flag for review

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