Focus: Fire-Life Safety / Column

Regulations, Codes & Standards Q&A: ABHR dispensers

Brad Keyes discusses regulations for ABHR dispensers

By Brad Keyes / Special to Healthcare Facilities Today


Q: In a business occupancy building, can alcohol-based hand-rub  (ABHR) dispensers be placed over carpeted area with no sprinklers?

A: Maybe yes and maybe no… It all depends on which AHJ is looking at your business occupancy.

Section 19.3.2.6 (8) of the 2012 LSC requires ABHR dispensers that are mounted over carpets, to only be in sprinklered smoke compartments. But this only applies to healthcare occupancies, and section 21.3.2.6 has similar language for ambulatory healthcare occupancies. The problem is, there is nothing written in chapters 38 or 39 regarding the installation of ABHR dispensers in business occupancies.

Since nothing is written in the business occupancy chapters, one may think there are no limitations, and the ABHR dispensers may be placed wherever you want without regard to regulations. Some AHJs may agree, and allow the ABHR dispensers be installed over carpet in an unsprinklered area. But the AHJs with healthcare experience and knowledge probably will not, based on their understanding of chapters 19 and 21. And, this is not an incorrect process, since they know these regulations regarding ABHR dispensers and can apply them to a business occupancy based on safety-related issues. Section 4.6.1.2 supports this concept.

But please understand, section 8.7.3.2 of the 2012 LSC prohibits the handling and storage of flammable liquids where it would jeopardize egress. This means ABHR dispensers are not permitted in egress corridor. Chapter 18/19 and 20/21 specifically permit ABHR dispensers in corridor so that over-rides section 8.7.3.2.  But the business occupancy chapters 38 and 39 do not have this language to over-ride 8.7.3.2, so that means ABHR dispensers are not permitted in egress corridor of business occupancies.

My advice is follow the same regulations for ABHR dispensers found in 19.3.2.6 for business occupancies, with the exception that ABHR dispensers are not permitted in egress corridors of business occupancies.  

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.

 

 



August 8, 2018


Topic Area: Regulations, Codes & Standards


Recent Posts

Building Envelopes Emerge As Key Facility Components

From enclosure commissioning and air-moisture control to decarbonization and thermal comfort, exterior systems affect energy efficiency and resilience.


Catholic Medical Center Breaks Ground on New Central Energy Plant

The new central energy plant is expected to be completed in early 2027.


Cottage Hospital Ensnared in Data Breach

On December 8, 2025, Cottage Hospital learned that an unauthorized party gained access to its computer network and took some of its files.


Biofilm 'Life Raft' Changes C. Auris Risk

Microscopic survival structure protects fungal pathogen from disinfectants and help it survive for long periods.


How Healthcare Restrooms Are Rethinking Water Efficiency

Manufacturers discuss strategies, technologies and design approaches that help healthcare facilities meet their sustainability goals.


 
 


FREE Newsletter Signup Form

News & Updates | Webcast Alerts
Building Technologies | & More!

 
 
 


All fields are required. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.