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Readily Accessible... in a cabinet?

Question asked by lloyd.abentroth on Oct 11, 2018
Latest reply on Jan 30, 2020 by chiefns830

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Would a GFCI outlet in a cabinet be considered readily accessible? Our local AHJ is saying no because homeowners will more than likely place items under the sink in front of the outlet. We do not understand how this is any different than many homeowners who will put free standing shelving, or permanently mounted shelving within the dedicated electrical space for a panel, yet those pass inspection! This is only an issue because we cannot find a 2/p AFCI/GFCI combo breaker to just please the local AHJ.

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steve.cardow Oct 11, 2018 7:36 PM
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So, first, he is correct in that would not meet the requirements of readily accessible. The reason is it is required for these devices and for resetting and monthly testing that is required as well. The only way to comply is by putting Combo AFCI/GFCI breaker in the panel, not sure why it is available for the brand you are using? If it were available you might be to use a blank AFCI/GFCI Combo device in a readily accessible location and feed through to your equipment which I presume is a pig?
Finally, the AHJ does have the final say and you could ask him for a recommendation he might have to satisfy the requirement?
Hope this helps!
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- upnorth @ steve.cardow on Jan 20, 2020 12:31 PM
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  A receptacle mounted inside a cabinet under a sink may be considered "readily accessible".
  Capable of being reached quickly for operation, renewal, or inspections without requiring those to whom ready access is requisite to take actions such as to use tools (other than keys), to climb over or under, to remove obstacles, or to resort to portable ladders, and so forth. NEC (2017): Art. 100, Part I, General Definitions.
  Worth noting that many would find that bending down to open a cabinet door to reach under a sink, to access a required GFCI receptacle, does not render it less than "readily accessible". Having receptacles installed or accessible inside kitchen cabinets is quite common, where wall space is at a premium and receptacles are required within 6 ft of any location along the base of the wall. A cabinet door is not "an obstacle" in the sense that it doesn't obstruct access.
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- srcardow @ steve.cardow on Jan 23, 2020 5:58 PM
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  Thought this sounded familiar posted 2018.
  steve.cardowOct 11, 2018 7:36 PM
  So, first, he is correct in that would not meet the requirements of readily accessible. The reason is it is required for these devices and for resetting and monthly testing that is required as well. The only way to comply is by putting Combo AFCI/GFCI breaker in the panel, not sure why it is available for the brand you are using? If it were available you might be to use a blank AFCI/GFCI Combo device in a readily accessible location and feed through to your equipment which I presume is a pig?
  Finally, the AHJ does have the final say and you could ask him for a recommendation he might have to satisfy the requirement?
  Hope this helps!
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rcramereleceng Jan 20, 2020 9:49 PM
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https://community.nfpa.org/message/64617?commentID=64617#comment-64617

The second entry by Mr. Hermanson details recent history for referenced Code interpretation -
what follows afterwards is an NEC Xchange Forum legacy discussion.
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chiefns830 Jan 21, 2020 11:54 AM
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To summarize the question -
It is not a whether-or-not-to-GFCI question, it is a "readily accessible" question. I would have to agree with upnorth that the GFCI receptacle below the sink may be considered as "readily accessible".
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rcramereleceng Jan 21, 2020 2:26 PM
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If I were asked the question straight-up as to whether the Receptacle below the Sink requires GFCI - my response would be of course!

When the argument is raised that it is difficult to reach for Resetting & Operational Confirmation then I have (2) solutions; either the Main Breaker is GFCI or the Receptacle below the Sink is on the Load Side (downstream) from a GFCI Receptacle along the Counter area.

[ a rhetorical statement (notice no question mark! ] I wonder if this one needs to be TR.
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chiefns830 Jan 22, 2020 4:12 PM
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The load circuit may not be able to be "shared." But one could always use blank face, on countertop, or wherever:

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rcramereleceng Jan 21, 2020 4:03 PM
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That's excellent Nick, I was unaware of this device.

[ This also solves that Garage Door Opener GFCI Receptacle false trips from Lightning if mounted external !! ]
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chiefns830 Jan 21, 2020 5:41 PM
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I used to use them all the time for hydromassage (bathtub w/jets) tubs. It beats having to get the access door off and sticking my head under there...for a simple reset.
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wjhammock Jan 24, 2020 10:16 AM
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AHJ has authority to make the 'readily accessible' determination, but you can request a formal interpretation from NFPA if you disagree with his decision. Per 2020 code article 422.16(B)(1) and (2) a receptacle is allowed under a kitchen sink for waste disposer and dishwasher if it is 'readily accessible'. The fact that it's allowed under the sink, at all, removes the objection that any outlet under a kitchen sink is not readily accessible.
Generally, I install a duplex receptacle under a sink, break the tabs, switch one side for the waste disposer, and use other side for dishwasher. Because the dishwasher has to be GFCI protected per 422.5(A), a GFCI receptacle is never used.
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chiefns830 Jan 24, 2020 10:25 AM
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That is incorrect, Wilbur. NEC 422.16(B)(1) and (2) does not say, "readily accessible." What it says is - "accessible." This is a totally different meaning. See definitions, Article 100:
"Accessible" vs. "Accessible, Readily"

Just because something is accessible doesn't mean that it is readily accessible.
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- wjhammock @ chiefns830 on Jan 24, 2020 2:54 PM
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  you are right Nick, thanks.
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lloyd.abentroth Jan 24, 2020 3:40 PM
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Update, we asked the local AHJ for his recommendation and he had none, this outlet is in an island of a 2nd story home with no possibility of running a separate line. We ran a 3 wire from the BR panel to the island to feed dishwasher and disposal on separate circuits. no backsplash so we used pop up outlets in countertop. AHJ allowed us to eliminate 1 circuit and install the dishwasher and disposal on same circuit and we installed combo breaker. We still install gfci outlets under the sink for dishwasher and disposal locally outside of his inspection area with no issues, even within the same building department. We have many issues locally with our inspectors, if you don’t know who’s inspecting the job you always risk a failed inspection or correction notice if you don’t satisfy their specific expectations... really bothersome that inspectors within the same department don’t follow the same interpretations. Did get clarification from NFPA and we were advised it is considered “readily accessible”.
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chiefns830 Jan 24, 2020 6:05 PM
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You are welcome, Wilbur

Lloyd, I agree with everything you say except for the last sentence. They (NFPA) would not be able to assume the role of the local AHJ, who is the only authority that can make the call as to whether something is "readily accessible."
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- upnorth @ chiefns830 on Jan 30, 2020 3:44 PM
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  "They (NFPA) would not be able to assume the role of the local AHJ, who is the only authority that can make the call as to whether something is "readily accessible."
  
  What he probably meant to say was that "in the opinion of the NFPA", a GFCI receptacle inside a cabinet beneath a counter would fall within the generally agreed definition of "readily accessible". An inspector who disagrees with that may find him or herself suspended for the necessary re-training.
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chiefns830 Jan 30, 2020 7:15 PM
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upnorth, I would have to disagree your last sentence, and your main point. But I'm always up for training anyway.
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- upnorth @ chiefns830 on Jan 30, 2020 10:17 PM
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  My point was that an inspector attempting to ignore or argue against a technical opinion of the NFPA regarding the basics, such as a definition of "readily accessible", let alone "accessible", could be something of a liability to the municipality's credibility among the trades, not to mention property owners. Learning how to choose your battles is part of effective law/code enforcement.
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chiefns830 Jan 30, 2020 11:24 PM
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No. I disagree 100%.

Furthermore, I never believed in "choosing battles." I won't go into detail, but I always call it as I see it, not worrying about the potential fallout prior to making any professional decision. If you like to "choose your battles" have at it. I treat everyone with fairness and impartiality.
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