To: Head of Fire Departments
From: Stephen D. Coan, State Fire Marshal
Date: June 1, 2003
Re: Alcohol-based hand cleaners used in health-care occupancies

This office has received numerous calls regarding the use of flammable alcohol-based hand rubs in health-care occupancies and the Board of Fire Prevention Regulations (527 CMR).

Alcohol-based hand cleaners, as defined by the Centers for Disease Control and Prevention (CDC), are an alcohol-containing preparation designed for application to the hands for reducing the spread of bacteria. These alcohol-based hand cleaners can be found in liquid, foam and gel forms. The cleaners usually contain 60% to 95% ethanol or isopropanol. The cleaners have flashpoints around 60° to 75° F, therefore making them Class 1 - Flammable Liquids. The volumes of the cleaner's dispenser range from small portable pocket sized containers to liter sized wall mounted hand pumped containers.

In October 2002, the CDC published the Guideline for Hand Hygiene in Health-Care Settings. In the guideline, the CDC has recommended the use of an alcohol-based hand cleaner for routinely decontaminating hands.

With the introduction of the cleaners in the healthcare occupancies, code concerns have risen regarding the permitting, the placement of the in-use containers and the storage of the not-in-use containers.

A permit from the Head of the Fire Department is required for the keeping and storage of up to 793 gallons of a Class I Flammable Liquid.

Placement for in-use containers:
The CDC recommends that the rubs be available at the entrance to the patient's room or at the bedside.

Although, not specifically addressed in 527 CMR, the following guidelines are recommended for the placement of the dispenser:

1. In the patient's room.

a. The dispenser should not be located near any possible ignition sources (i.e. high temperatures, electrical sockets, electrical equipment, heaters, etc…).
b. The dispenser should not be located near any oxygen dispensing equipment.

2. In the corridor.

a. The corridor should either:

i. Be protected by a sprinkler system.
ii. Be protected by a smoke detection and notification system.

b. The corridor should be provided with the appropriate fire extinguishers.
c. The container shall contain no more than 800 ml (27.04 FL OZ).
d. The dispenser should not be located near any possible ignition sources (i.e. high temperatures, electrical sockets, electrical equipment, heaters, etc…).
e. The dispenser shall not project out into the corridor more than 4 inches.
f. The emergency evacuation plan should be updated and reviewed (527 CMR 10.08 and 10.13).

Storage of the not-in-use containers
The storage of the not-in-use containers shall be in accordance with 527 CMR for flammable liquid storage.

  • The storage shall not be placed in a means of egress (527 CMR 10.03(13)(b)).
  • The head of the fire department may limit the quantities (527 CMR 14.03(5)).
  • Storage should not be more than 120 gallons in a storage cabinet (527 CMR 14.03(18)(c), 2000 NFPA 30: 4.3 and

The storage of the not-in-use containers exceeding 30 gallons will require conformance with 780 CMR and a building permit may be required to be obtained.

Several national fire and health organizations along with a testing agency are currently investigating the rubs for their fire potential and possible code impact. When more specific information becomes available, this office will relay it to you.

If you have any questions, please contact Jacob Nunnemacher, Fire Protection Engineer, at (978) 567-3377.