Interpretation #: CEB-2021-04-2009 IEC-422.31(B)

Building or Fire Safety Law Interpreted

675 IAC 17-1.8 2009 Indiana Electrical Code Article 422.31 Disconnection of Permanently Connected Appliances

For permanently connected appliances rated over 300 volt-amperes or 1/8 hp, the branch-circuit switch or circuit breaker shall be permitted to serve as the disconnecting means where the switch or circuit breaker is within sight from the appliance or is capable of being locked in the open position. The provision for locking or adding a lock to the disconnecting means shall be installed on or at the switch or circuit breaker used as the disconnecting means and shall remain in place with our without the lock installed.

Issue

Whether a lock placed on the electrical panel door, or a locking electrical panel door, meets the 2009 Indiana Electrical Code (IEC) Article 422.31(B) requirement for location of locking provisions at the disconnecting means of permanently connected appliances that are rated in excess of 300 volt-amperes or 1/8 horsepower.

Interpretation of the State Building Commissioner

A lock placed on the electrical panel door, or the installation of a locking electrical panel door, does not meet the 2009 IEC Article 422.31(B) requirement for location of locking provisions at the disconnecting means of permanently connected appliances rated in excess of 300 volt-amperes or 1/8 horsepower.

Rationale

The language of the code is clear on this issue. It states that "the provision for locking or adding a lock. . .shall be installed on or at the switch or circuit breaker used as the disconnecting means." The requirement is that the locking device be placed at the switch or breaker itself. Locking the door to the electrical panel does not meet this requirement, any more than would a lock on the door of the room that contains the electrical panel. Further, locking the electrical panel door prevents access to the remainder of the breakers in the panel, at a time when access may be required for other purposes, perhaps even in emergencies. It is unreasonable to expect that while installation or repairs on hardwired appliances are taking place, no one else would require access to the electrical panel.