My March 16th article about the hand sanitizers being a CAT 3 Flammable Liquid caused quite the ruckus. Many did not want to accept the fact until they went and found out on their own that these alcohol-based hand sanitizers are indeed flammable liquids. And once they came to this realization the questions started to pour in. The International Fire Code (I am using the 2018 edition) has two (2) sections specific to these alcohol-based hand sanitizers, which is more helpful than trying to apply OSHA’s 1910.106. The IFC provides several specific prohibitions as to where these hand sanitizer dispensers may be located; such as dispensers shall not be installed above, below, or closer than 1 inch to an electrical receptacle, switch, appliance, device or other ignition sources. The wall space between the dispenser and the floor or intervening countertop shall be free of electrical receptacles, switches, appliances, devices or other ignition sources. Now that you have that mental image in your head, how many dispensers have you seen mounted within 1″ of an electrical receptacle, switch, appliance, device or other ignition sources?
5705.5 Alcohol-based hand rubs classified as Class I or II liquids.
The use of wall-mounted dispensers containing alcohol-based hand rubs classified as Class I or II liquids (or as OSHA calls them CAT 2 or 3 liquids) shall be in accordance with all of the following:
1. The maximum capacity of each dispenser shall be 68 ounces (2 L).
2. The minimum separation between dispensers shall be 48 inches (1219 mm).
3. The dispensers shall not be installed above, below, or closer than 1 inch (25 mm) to an electrical receptacle, switch, appliance, device or other ignition sources. The wall space between the dispenser and the floor or intervening counter top shall be free of electrical receptacles, switches, appliances, devices or other ignition sources.
4. Dispensers shall be mounted so that the bottom of the dispenser is not less than 42 inches (1067 mm) and not more than 48 inches (1219 mm) above the finished floor.
5. Dispensers shall not release their contents except when the dispenser is manually activated. Facilities shall be permitted to install and use automatically activated “touch free” alcohol-based hand-rub dispensing devices with the following requirements:
5.1. The facility or persons responsible for the dispensers shall test the dispensers each time a new refill is installed in accordance with the manufacturer’s care and use instructions.
5.2. Dispensers shall be designed and must operate in a manner that ensures accidental or malicious activations of the dispensing device are minimized. At a minimum, all devices subject to or used in accordance with this section shall have the following safety features:
5.2.1. Any activations of the dispenser shall only occur when an object is placed within 4 inches (98 mm) of the sensing device.
5.2.2. The dispenser shall not dispense more than the amount required for hand hygiene consistent with label instructions as regulated by the United States Food and Drug Administration (USFDA).
5.2.3. An object placed within the activation zone and left in place will cause only one activation.
6. Storage and use of alcohol-based hand rubs shall be in accordance with the applicable provisions of Sections 5704 and 5705.
7. Dispensers installed in occupancies with carpeted floors shall only be allowed in smoke compartments or fire areas equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2
5705.5.1 Corridor installations.
In addition to the provisions of Section 5705.5, where wall-mounted dispensers containing alcohol-based hand rubs are installed in corridors or rooms and areas open to the corridor, they shall be in accordance with all of the following:
1. Level 2 and 3 aerosol containers shall not be allowed in corridors.
2. The maximum capacity of each Class I or II liquid dispenser shall be 41 ounces (1.21 L) and the maximum capacity of each Level 1 aerosol dispenser shall be 18 ounces (0.51 kg).
3. The maximum quantity allowed in a corridor within a control area shall be 10 gallons (37.85 L) of Class I or II liquids or 1135 ounces (32.2 kg) of Level 1 aerosols, or a combination of Class I or II liquids and Level 1 aerosols not to exceed, in total, the equivalent of 10 gallons (37.85 L) or 1,135 ounces (32.2 kg) such that the sum of the ratios of the liquid and aerosol quantities divided by the allowable quantity of liquids and aerosols, respectively, shall not exceed one.
4. The minimum corridor width shall be 72 inches (1829 mm).
5. Projections into a corridor shall be in accordance with Section 1003.3.3.
Item 1 prohibits the use of Level 2 and 3 aerosol alcohol-based hand rub dispensers in exit access corridors because aerosol containers were not considered in the fire modeling for the original project. This exclusion is appropriate for Level 2 and 3 aerosols but not for Level 1 aerosols because they are treated as ordinary combustibles by the code. Their alcohol content is equal to that currently permitted in Class I and II liquid or gel hand sanitizers. The aerosol industry was asked to conduct its own study and testing to show that aerosols could also be allowed in the same application. The study determined that the hazard of Level 1 aerosols was less than that of the allowed Class I and II liquid or gel hand sanitizers and
that the aerosol can would not release its contents before the temperatures in the corridor became untenable.
Item 2 is based on the fact that the fire modeling and aerosol industry test results indicated that both ethyl and isopropyl alcohol-based products and aerosols met the tenability criteria when controlled in volume to 41-ounce (1.21 L) liquid and 18-ounce (509 g) aerosol dispenser containers in corridors. For aerosols, the capacity is based on typical industry containers.
In arriving at Item 3, based on usage patterns, primarily in health care occupancies, it was felt that establishing a 10-gallon (38 L) allowable amount or combined liquid and aerosol equivalent allowable amount, which is well below the MAQs for Class I or II liquids in Table 5003.1.1(1), is reasonable and safe for any occupancy. A simple method of calculating
the maximum allowable quantity of combined liquids and aerosols is provided and is based on IBC Section 508.4.2. For example, if 4 gallons (15 L) of liquids and 500 ounces (14 175 g) of aerosols were present, 4/10 plus 500/1135 is less than one and, therefore, below the maximum combined allowable quantity.
Item 4 is based on the performance of the dispenser containers in the fire modeling scenarios.
Item 5 is intended to prevent dispensers from projecting into areas over walking surfaces as regulated in Section 1003.3.3. See the commentary for Section 1003.3.3 for further discussion of projections into the required width of corridors.
Another great source for controlling these hazards is the NFPA 101 Life Safety Code Requirements for the use of Alcohol-based hand sanitizer (ABHS) Dispensers
| Criteria | Requirement |
|---|---|
| Hand rub solution | Must not exceed 95% alcohol content by volume. (The Centers for Disease Control and Prevention recommends that ABHS contain at least 60% alcohol.) |
| Maximum dispenser fluid capacity | 1.2 liters (41 ounces, 0.32 gal) for dispensers in rooms, corridors, and areas open to corridors. 2.0 liters (67 ounces, 0.53 gal) for dispensers in suites of rooms separated from corridors. |
| Maximum quantity in aerosol containers | 18 oz., limited to Level 1 aerosols as defined by NPFA 30 B. |
| Maximum quantity of ABHS allowed in-use (i.e., in dispensers) | Ten gallons (37.8 L) in-use outside of a storage cabinet within a single smoke compartment. (Smoke compartment: A space within a building enclosed by smoke barriers on all sides, including the top and bottom.5) One dispenser per room off corridors is NOT included in the calculation. |
| Minimum corridor width | Six feet (1830 mm) wide |
| ABHS dispenser distance from ignition sources | One-inch (25 mm) distance (horizontal or vertical) above, to the side, or beneath an ignition source. (Sources of ignition: Appliances or equipment that, because of their intended modes of use or operation, are capable of providing sufficient thermal energy to ignite flammable gas-air mixtures.5 Examples include wall outlets, thermostats, and appliances.) Note: While one-inch is acceptable, a more conservative approach is to ensure a distance of no less than 6 inches (12.7 mm; horizontal or vertical, measured from the center of the dispenser) between ABHR dispensers and source of ignition. |
| ABHS dispenser separation | Horizontal spacing not less than 48 inches (1220 mm). |
| Carpeted areas | The smoke compartment must be equipped throughout with an approved automatic sprinkler system. |
| Operation of the dispenser |
The dispenser shall:
Any activation of the dispenser shall only occur when an object is placed within 4 inches (100mm) of the sensor.
An object placed within the activation zone and left in place shall not cause more than one activation. |
| Storage outside of dispensers | In each smoke compartment, do not store outside of dispensers more than 5 gal (18.9 L) or an amount of ABHR that exceeds that which is necessary for normal maintenance of the area, whichever is less. |
| The maximum quantity for storage in a warehouse | Up to 120 gal (460 L). If need to exceed storage of 120 gal (460 L), consult with fire official.4 |
*Smoke compartment: A space within a building enclosed by smoke barriers on all sides, including the top and bottom.5
**Sources of ignition: Appliances or equipment that, because of their intended modes of use or operation, are capable of providing sufficient thermal energy to ignite flammable gas-air mixtures.5 Examples include wall outlets, thermostats, and appliances.
CLICK HERE for more on the flammability of alcohol-based hand sanitizers from the CDC