OSHA provides working space clearances based on the National Electrical Code’s Table 110.26(A)(1) and 110.26(A) and (B). 110.26(C) also addresses entrance to and egress from the working space.
The spaces in Table 110.26(A) are based on preventing electrical shock and are permanent distances. However, other hazards and permanent spaces may be compromised by temporary problems. A similar situation arises with the ingress/egress spaces addressed by 110.26(C).
Consider an equipment closet in a commercial building. All the electrical gear, such as transformers and panels, were installed in compliance with Table 110.26(A)(1), 110.26(A), 110.26(B), and 110.26(C). When the contractor left, the equipment closet was Code-compliant.
The tenant did not leave it that way. An often-overlooked requirement is that the space be “maintained” [110.26]. In this instance, the tenant stacked file boxes in the 30-inch doorway. Even though these were off to one side, they dangerously narrowed the effective doorway space. An electrician sidling through it for the umpteenth time banged his hip hard on the metal frame. Fortunately, he was only bruised. But he could have suffered a fracture or dislocated his hip trochanter.
If he had broken his hip, whose fault would that have been? Legally, it's the responsibility of the tenant. But had the electrician simply moved the boxes out of the way or asked the tenant to do so, he would not have been injured. The pain of a hip fracture is intense. The recovery is long, difficult, and painful. No award from a civil suit can make up for that. It is much better to take responsibility for preventing the injury by removing the hazard.
And what if he’d fallen into the room after breaking his hip? Somebody would have to remove all that stuff so EMTs or other qualified responders could get him out of the room without compounding the injury.
In a manufacturing plant, an electrician was trying to solve a problem with a control system for a production machine. The operator seemed to be channeling a housecat. Every time the electrician turned around, he just about tripped over the operator. At one point, the electrician pivoted out of the way, lost his balance, and fell onto the machine. Whose fault was this? Sure, the operator was causing the hazard. But the electrician didn’t do anything about it. He could have taken these steps to ensure he had adequate space to work:
- Tell the operator why he’s causing safety and concentration problems. Ask the operator to stand back at least 6 feet.
- Rope off the area, then tell the operator he can’t enter.
- If the operator persists, stop work and contact the operator’s supervisor or his own supervisor.
Residential working space
A residential electrician was sent to a home to replace the blower motor in the furnace, located in the unfinished basement. His first problem was the dingy lighting provided by a single 40W bulb; this violated 110.26(D), which requires sufficient illumination. So, he went to the truck to get his portable lights. As he was setting them up, he noticed the furnace was completely surrounded by storage boxes. And the clutter between the basement entry and the furnace left no path for safely entering and leaving the area while carrying old and new parts.
He told the homeowner he needed sufficient space and those boxes would have to be moved. The homeowner resisted this idea, so the electrician asked, “How do you get to this thing to change the filter?” It turned out that the filter had never been changed, which led to the burn-up of the blower motor. The homeowner had not left sufficient space for maintenance or repair.
When assessing whether you have adequate space for installing, maintaining, or repairing equipment, you must consider more than whether the permanent and energized equipment conforms to Table 110.26(A)(1).
Working space is often choked by items that can simply be moved or people who don’t need to be there. Rather than work around the objects, ensure they are moved out of the way. Stumbling around them, squeezing past them, or stepping over them are all ways of playing in the injury casino. And the house will eventually win.
When people, regardless of their good intentions, don’t need to be there and are in your otherwise adequate space, you have every right to thank them for their concern and then ask them to leave. If they don’t leave, you do not have an obligation to tolerate their interference. Your responsibility is to ensure they don’t have to go home that day knowing they were the reason you were injured.
