Q: Are ladders allowed to be stored in electrical closets as long as the egress path is maintained and the 3ft clearance is applied? We had an inspector site 1910.303(g)(1)(ii) “Working space required by this standard may not be used for storage.” I referenced NFPA 70-2011 section 110.26 regarding the clearance which permits ladder storage but the surveyor ignored it. All our rooms are sprinklered and 1-hour fire rated.
A: The most restrictive requirement applies… You are correct that NFPA would permit storage of ladders in the electrical closet provided clearance to all electrical equipment is maintained. But this particular surveyor knew the OSHA requirements, and section 1910.303(g)(1)(ii) does prohibit storage in the electrical room.
It’s frustrating when you work hard to be in compliance with all NFPA codes and standards just to find out you are out of compliance with OSHA. If this was a CMS state agency survey or an accreditation survey, then I would say this finding is legitimate because 18.104.22.168 of the 2012 LSC says any requirements that are essential for the safety of the building occupants and that are not specifically provided for in this LSC, shall be determined by the AHJ. The surveyor, who is the AHJ, apparently did determined that the OSHA standard 1910.303(g)(1)(ii) is essential for your safety, and therefore it applies.
I guess you will have to deal with it and find a new home for ladders. Also, better post signs inside your electrical room advising everyone to not store anything in the room.
NOTE: Since this article was posted, I have received numerous comments from people much smarter than I on OSHA requirements, stating they believe the surveyor was incorrect in his citation. According to the readers, OSHA says if the ladder is not in the working space then they think that it should be permitted.
Please use your own best judgement when considering any changes to storage in electrical rooms.