Can a subpanel for a hot tub be locked?

Question

I am a property manager in N.C. and I have a vacation rental property owner who insists on putting a combination lock on the sub panel for his hot tub. I've been researching and am getting conflicting answers for the rules/laws on this. My hot tub guy says it's illegal to put a lock on a subpanel and that it has to be accessible for emergency reasons. Can someone tell me the correct answer for this?

Answer 1

Based on NEC 240.24(B) (multiple references, multiple years):

Occupancy. Each occupant shall have ready access to all overcurrent devices protecting the conductors supplying that occupancy, unless otherwise permitted in 240.24(B)(1) and (B)(2).

240.24(B)(1) is for feeders in a multi-tenant building - i.e., each tenant has to be able to access their own panel but not the main feeder for the building.

240.24(B)(2) is specifically for guest rooms or guest suites with no cooking. Which might apply, for example, to a hotel.

In both cases they are based on "under continuous building management supervision", which certainly doesn't apply to a typical single rental property (as opposed to a hotel or apartment building).

Answer 2

NEC 2023

Article 680 Swimming Pools, Fountains, and Similar Installations
Part IV Permanently Installed and Self-Contained Spas and Hot Tubs and Permanently Installed Immersion Pools
680.40 General Electrical installations at spas and hot tubs shall comply with the provisions of Part I and Part IV of this article.

Part I General
680.13 Maintenance Disconnecting Means One or more means to simultaneously disconnect all ungrounded conductors shall be provided for all utilization equipment other than lighting. Each means shall be readily accessible and within sight from its equipment and shall be located not less than 1.5 m (5 ft) horizontally from the inside walls of a pool, spa, fountain, or hot tub unless separated from the open water by a permanently installed barrier that provides a 1.5 m (5 ft) reach path or greater. This horizontal distance shall be measured from the water's edge along the shortest path required to reach the disconnect.

Article 100 Definitions

Accessible, Readily (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. (CMP—1)

So is a combination lock equivalent to a key?

90.4 Enforcement.(B) Interpretations. The authority having jurisdiction for enforcement of the Code has the responsibility for making interpretations of the rules, for deciding on the approval of equipment and materials, and for granting the special permission contemplated in a number of the rules.

So you need to ask the local Electrical Inspector! Really this is just a jurisdiction issue, the NEC is a privately produced document by the NFPA, and is only law if, when, and as exceptions noted are adopted by local authorities.