Do you have to provide an electrical disconnect for a body of water?

A number of players in the industry, including some on the Code Making Panel that wrote the rule, have requested we analyze the revised wording of Sec. 680-12 in terms of exactly where you have to provide the disconnect covered in that section. We regret to report that the literal text leads to even more confusion than the original 1996 version. Compare the two versions:

Disconnecting Means. Disconnecting means shall be accessible, located within sight from pool, spa, and hot tub equipment, and shall be located at least 5 ft horizontally from the inside walls of the pool, spa, or hot tub. [1996 NEC]

Disconnecting Means. A disconnecting means shall be provided and be accessible, located within sight from all pools, spas, and hot tub equipment, and shall be located at least 5 ft from the inside walls of the pool, spa, or hot tub. [1999 NEC]

The EC&M panel's response. The 1996 proposal submitter wanted to be able to work on spa and hot tub equipment safely without requiring access to the inside of a residence. In some cases, installers would place the controller for an outdoor hot tub, for example, in a locked basement. Long standing rules in Art. 430 allow disconnects to be out of sight of motors as long as the required controller disconnect, which must be in sight of its controller, can be locked open. The wording clearly aimed at Sec. 430-102(b) Ex. for motors. Heating equipment, if on a separate branch circuit from the motors, should certainly be affected as well, since Sec. 422-31(b) normally allows a simple lockout on the circuit-breaker.

There were two problems, however, with the 1996 wording. First, it covered all equipment, which as defined in Art. 100 brought in lighting and other innocuous loads. Second, it utterly failed in its stated purpose, since it didn't actually require you to provide a disconnect. It only told you where to put the disconnect, should you have chosen to provide it.

The 1999 NEC unarguably requires you to provide the disconnect. With no question, that is fixed. Without substantiation, however, the word form of the key words in the rule, "pool" and "spa," changed from the singular to the plural. This changed those words from adjectives describing the noun "equipment" to nouns in their own right, since in the plural form and in this context they can't be modifiers. [Note: Although unsubstantiated, the 1999 deletion of the word "horizontally" has no substantive effect, because it's still there in Sec. 680-6(c) and -41(c).]

On the literal text, you need a disconnect in sight of all "pools"; in sight of all "spas"; and in sight of all "hot tub equipment." This is both grammatically correct and technically ridiculous, since the whole point was to protect workers maintaining equipment associated with pools and spas, as well as hot tubs. Some spas and many pools have their equipment in outbuildings or basements, well out of sight of the body of water. In addition, Art. 680 throughout treats spas and hot tubs consistently in terms of technical requirements. (Note: Don't confuse this rule with Sec. 680-38, which has a completely different function.)

Another possibility would be to pretend those two terms weren't made plural. That would make technical sense, but it would also make a substantive change by removing the requirement for a disconnect in sight of the body ofwater. The most conservative approach would be to set disconnects in sight of both the bodies of water and in sight of the equipment, if they aren't in the same location.

We think the only sensible approach is to pretend the terms are still adjectives. That covers the only technical issue publicly substantiated. Clearly CMP 20 needs to address, in a documented way, the technical merits of literally providing in-sight disconnects for bodies of water, as well as for more innocuous loads such as lighting. This only if, of course, an equipment disconnect isn't enough.