Hot tubs and spas in unincorporated Shelby County follow the adopted Memphis and Shelby County Residential Code. A spa needs a barrier like a pool unless it has an approved safety cover, and electrical work must be permitted and inspected.
The adopted IRC treats spas and hot tubs as pools for barrier purposes: the barrier requirements of Section AG105 apply to any hot tub or spa. However, a spa or hot tub equipped with a safety cover that complies with ASTM F1346 is exempted from the barrier requirement. All spa and hot tub electrical work, including the required equipotential bonding, GFCI protection, and any disconnect, is governed by the Memphis and Shelby County Electrical Code referenced in Residential Code Chapter 42 and must be inspected before use. Permit thresholds mirror pools: a small prefabricated unit less than 24 inches deep is exempt from a building permit, but the electrical work still requires a permit and inspection.
A spa left uncovered without a compliant barrier is a barrier violation that fails inspection. Uninspected or unbonded spa wiring is an electrical code violation enforceable by Construction Code Enforcement.
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