You're right to focus on accessibility when considering a LOTO switch on the side of a control panel. While 110.26 primarily addresses working clearances in front of electrical equipment for servicing and maintenance, the accessibility of a LOTO device falls under a different (though related) area of concern: effective lockout/tagout procedures.Here's a breakdown: NEC 110.26 primarily addresses working clearances for servicing equipment. It mandates minimum distances from the front of the equipment to ensure electricians can safely perform maintenance, repairs, and installations. It's not directly applicable to the side of the equipment just for operating a LOTO switch, nor does the NEC specifically address the LOTO switch clearances. OSHA's Lockout/Tagout Standard (29 CFR 1910.147) is key here. While OSHA doesn't provide specific measurable dimensions for LOTO switch accessibility in the same way the NEC provides clearance distances, it emphasizes that LOTO procedures must be effective and enforceable. This means the switch must be readily accessible to authorized employees who need to isolate energy sources. The "Easily Accessible" Consideration

This is the crux of the issue. "Easily Accessible" is subjective, but here's how you can approach it:

Obstructions

Is the side of the panel obstructed by anything that would hinder a worker from quickly and safely reaching the LOTO switch? Consider piping, conduit, other equipment, structural elements, etc. If obstructions exist, the accessibility is compromised.

Height

Is the switch located at a reasonable height for most employees to reach and operate without difficulty? Excessively high or low placements are problematic. Ideally, the switch should be within a comfortable reach range for the anticipated user population (consider the 5th to 95th percentile reach ranges). A reasonable height might be between 3-6 feet from the floor, but that depends on the specific context.

Clarity and Visibility

Is the switch clearly labeled and readily visible? Poor lighting, obscured labeling, or a hard-to-find location make the switch less accessible.

Usability with PPE

Can the switch be easily operated while wearing required Personal Protective Equipment (PPE), such as gloves? Small, recessed, or awkwardly positioned switches may be difficult to use with gloves.

Surrounding Environment

Is the area around the side of the panel free of hazards (e.g., slip/trip hazards, sharp edges, moving machinery) that could compromise safety while operating the switch?

In summary


NEC 110.26 isn't the primary concern here. It addresses working clearances for servicing, not LOTO switch accessibility.2. OSHA 1910.147 is the governing standard. While it doesn't provide specific measurements, it mandates effective and enforceable LOTO procedures.3. "Easily Accessible" requires a practical assessment. Consider obstructions, height, visibility, usability with PPE, and the surrounding environment. Document your rationale for why the location meets the intent of OSHA's requirement.

Recommendations



Perform a Risk Assessment

Evaluate the potential hazards associated with operating the LOTO switch in its current location. Identify any factors that could hinder accessibility or increase risk.

Involve Employees

Get feedback from the employees who will be using the LOTO switch. Their experience and insights are valuable.

Consider Alternatives

If the current location is problematic, explore alternative placements for the LOTO switch that would improve accessibility and safety. This could involve relocating the switch, adding a remote operator, or modifying the surrounding environment.

Document Your Assessment

Keep a written record of your assessment, including the factors you considered and the rationale for your decision. This documentation can be invaluable if you're ever questioned about the accessibility of the LOTO switch.*

Consult with a Safety Professional: If you're unsure whether the LOTO switch location meets the intent of OSHA's requirements, consult with a qualified safety professional.By focusing on the principles of effective lockout/tagout and conducting a thorough assessment of the LOTO switch location, you can ensure that it is readily accessible and safe to use. Remember, the goal is to protect employees from hazardous energy during servicing and maintenance. Flag for review