Should a situation arise that leaves you looking for an exit out of harm’s way, your egress path must be secure and clear, and the egress door must function and lead to safety. When performing electrical work, or any type of work for that matter, an effective means of egress can mean the difference between life and death. This appears to be a seemingly simple topic of emergency egress, but one that should not be assumed. Let’s review this topic and uncover topics for you and your team to consider when planning your next electrical project.
Codes and Standards
When thinking about egress and electrical safety, the National Electrical Code (NEC) immediately comes to mind to see what sections help to ensure the installation provides attention to egress. Section 110.26(C), “Entrance to and Egress from Working Space” is the first section that needs to be considered. This section has a minimum requirement of having at least one entrance of sufficient area to provide access to and egress from working space about electrical equipment. There is currently special consideration given to equipment 1,200 Amps and higher and larger than 6 feet wide. But these requirements have not been there since day one. We have to look back to understand some of the history as the facilities we work in are not all built to the latest code.
The history of this section of the Code shows a requirement for at least one entrance of sufficient area beginning with NEC 1965. Back then it was Section 110-16(C). NEC 1978 saw a change to this section placing a different requirement for control panels rated 1,200 Amps or more and of a size over 6 feet wide. This change was such that it called out for an entrance not less than 24 inches wide at each end where reasonably practicable. Proposal number 100 during the NEC 1978 code cycle, initially rejected, sought to require no less than two exits where equipment is over 800 amperes and more than 6 feet wide. This proposal from the Arizona Chapter of the International Association of Electrical Inspectors (IAEI) was submitted with a substantiation that stated that at least two exits were required for this equipment for electrical worker safety. The submitter noted, “Several people have almost burned to death when they were trapped in the back of such equipment rooms with the equipment burning between them and the only way out.” This proposal was rejected with a panel comment noting, “The specific proposal is impractical and gives no guidance as to where the exits should be placed. The subject may deserve further study, and comments would be helpful.” The panel eventually settled on the final accepted language:
“(C) Access and Entrance to Working Space.
At least one entrance of sufficient area shall be provided to give access to the working space about electric equipment. For switchboards and control panels rated 1200 amperes or more and over 6 feet wide, there shall be one entrance not less than 24 inches wide at each end where reasonably practicable.”
This language was in place until NEC 1984 when the “where reasonably practicable” verbiage came under fire and was replaced with some exceptions. The substantiation for the proposals that were accepted at this time noted that these words were vague and often unenforceable. The two exceptions that were added to replace “where reasonably practicable” were:
Exception No. 1: Where the equipment location permits a continuous and unobstructed way of exit travel.
Exception No. 2: Where the work space required by Section 110.16(a) is doubled.
Receiving continued attention, NEC 1987 attempted to address the issue of where the entrance should be located. The substantiation provided for the accepted proposal noted that the existing language of the section would permit the entrance opening to be located at or up against the electrical equipment. The concern of the submitter was that in the case of equipment burn-up, the emergency egress could be obstructed by the burning equipment. The submitter supported this reasoning by providing a real-life example from a potato processing plant. The submitter noted, “A fireman was trapped in a working space where two control panels faced each other with the proper working clearance between. The burn-up extended into the entrance, and the fireman was trapped inside.” The fireman in this case was not killed but was severely burned. NEC 1987 modified the language to add the following clarification for the location of the exit:
“Working space with one entrance provided shall be so located that the edge of the entrance nearest the switchboards and panelboards is the minimum clear distance given in Table 110-16(a) away from such equipment.”
Over the years this section received continued attention to refine the language. The NEC 2014 code cycle did not disappoint in this department. It appears that language change was accepted to move the 1,200 Amp number in this section 110.26(C) to 800 Amps. As noted above, the 800 Amp number appeared in the IAEI proposal during the NEC 1978 revision cycle. The current NEC 2011 language of the code notes that you must have unobstructed egress or extra working space to permit a single entrance into an electrical room when the equipment is large and of high amperage.
(C) Entrance to and Egress from Working Space.
1. Minimum Required. At least one entrance of sufficient area shall be provided to give access to and egress from working space about electrical equipment.
2. Large Equipment. For equipment rated 1,200 amperes or more and over 1.8m (6 ft.) wide that contains overcurrent devices, switching devices, or control devices, there shall be one entrance to and egress from the required working space not less than 610mm (24 in.) wide and 2.0m (6 1/2 ft.) high at each end of the working space.
A single entrance to and egress from the required working space shall be permitted where either of the conditions in 110.26(C)(2)(a) or 110.26(C)(2)(b) is met.
(a) Unobstructed Egress. Where the location permits a continuous and unobstructed way of egress travel, a single entrance to the working space shall be permitted.
(b) Extra Working Space. Where the depth of the working space is twice that required by 110.26(A)(1), a single entrance shall be permitted. It shall be located such that the distance from the equipment to the nearest edge of the entrance is not less than the minimum clear distance specified in Table 110.26(A)(1) for equipment operating at that voltage and in that condition.
These are code requirements and not work practices. The installation may or may not have two entrances and may or may not have unobstructed egress. It depends on when the installation was performed, what version of the code was adopted for that jurisdiction, and if a version of the code was even adopted. Then, there is the enforcement issue: Whether or not there is an enforcement requirement for that jurisdiction. The bottom line is that your work practice must include a verification of egress for the work you are about to perform.
Develop Your Egress Plan
Your safety plan should include attention to emergency egress for electrical work that is being performed. Let’s take some guidance from the Life Safety Code, NFPA 101. The Life Safety Code addresses construction, protection, and occupancy features that minimize danger to life from fire and nonfire emergencies. This document considers the hazards of smoke, heat, and toxic gases that are created during a fire and works to facilitate prompt escape of occupants from buildings or into safe areas within buildings. Chapter 7 of the Life Safety Code defines a means of egress as a “continuous and unobstructed way of travel from any point in a building or structure to a public way consisting of three separate and distinct parts: (1) the exit access, (2) the exit, and (3) the exit discharge.” Let’s break this down into parts and consider this definition with respect to our task at hand, emergency egress plans for use during planned electrical work. Your plan should address the following four key topics:
- Continuous and Unobstructed
The use of “continuous” and “unobstructed” may sound simple and straightforward, but they may be quite challenging to achieve in some situations. It is not enough to simply look at a drawing to determine if your way of travel is continuous and unobstructed. Obstructions can be walls or other structural components but more often than not, obstructions include boxes, equipment, or other similar items that do a very good job of obstructing your exit path but are not included on drawings as they are not structural components. In some instances, these obstructions could be the very tools or equipment we bring to get the job done. Before beginning work, you should observe and ensure everyone knows their locations/paths of exit and check that they are continuous and unobstructed. Review the location of work and observe any areas of concern that could obstruct an emergency egress. Everyone on the job has to understand the common goals because any one person, while work is being performed, may mistakenly obstruct the exit path. All it takes is a ladder, tool box, or other equipment in the wrong place to impede your efficient exit should the need arise. Keeping your egress path continuous and unobstructed is a team effort.
- Exit Access
Your exit access is every inch of ground between you and the exit door. Just seeing the exit is not enough. The previous discussion, continuous and unobstructed, is pertinent to exit access. Your exit access status can change at any time while work is being performed. Everyone must understand that your egress route needs to be clear and unobstructed. Everyone must know the route to the exit. Walk from the work area to the exit that is planned to be used. Make sure it labeled and visible, and the entire access way is clear. Review this with your team.
- The Exit
Sometimes visual inspections are not adequate to ensure a means of egress. For example, if your egress door is an exterior door or one that hasn’t been opened in quite some time, the door may be seized and unable to open. The door hardware may not be functioning or may be obstructed. Before beginning work, check that your exit doors are working properly and that they open in the direction of egress. Confirm that panic hardware works properly as well. This will require you to exercise the door to make sure it opens before your work begins.
- Exit Discharge
Once you hit that exit door and proceed, what is on the other side is very important. NFPA 101 defines the exit discharge as that portion of a means of egress between the termination of an exit and a public way. Your exit discharge from your work area must get you out of harm’s way and not into another problem area. After exercising the exit in step three above, review the area into which it opens. Check that its location is adequate to meet your needs. Consider all possible failure modes and ramifica- tions of that failure. For example, if the equipment you are working on fails, and it controls a process that will empty into an area on the other side of the exit door you planned to use, that door may not be a good option for emergency egress. In many cases, you will only have one door to pick from. Depending upon the hazard and the work being performed, one single door may not be enough to ensure you are cleared from danger. A problem may arise that gives you cause to leave the building and not just the room in which you are located.
Keep an open mind on all possible problems that may arise when choosing your means of egress from your work location. Choosing your exit wisely takes into consideration all four separate and distinct parts discussed above. The discussion of emergency egress should be discussed before your work begins, and your entire team must understand the plan and your goals.
Emergency egress is not a simple topic and one that needs to be addressed before your work begins. After all, we review where the exits are at the beginning of most meetings to establish that everyone knows how to exit should an emergency occur. Why wouldn’t you make this a point to review before your work begins? When an emergency occurs, your egress plans need to have been well thought out. It could mean the difference between life and death.
As always, keep safety at the top of your list, and ensure you and those around you live to see another day. If you have any tips or ideas you would like to share, please feel free to send them to me at firstname.lastname@example.org. I look forward to your input to these articles and guidance for future articles.
Thomas Domitrovich, P.E., is a National Application Engineer with Eaton Corporation (an IEC National Platinum Partner) in Pittsburgh, Pennsylvania. He has more than 20 years of experience as an Electrical Engineer and is a LEED Accredited Professional. Thomas is active in various trade organizations on various levels with the Independent Electrical Contractors (IEC), International Association of Electrical Inspectors (IAEI), Institute of Electrical and Electronic Engineers (IEEE), National Electrical Manufacturer’s Association (NEMA), and the National Fire Protection Association (NFPA). Thomas is involved with and chairs various committees for NEMA and IEEE and is an alternate member on NFPA 73. He is very active in the state-by-state adoption process of NFPA 70 by working closely with review committees and other key organizations in this effort.