Author(s): Kristin Bigda. Published on November 1, 2020.

In Compliance | NFPA 101

Alcohol-based hand sanitizer, part I: life safety considerations


These days, it’s hard to walk through just about any type of building—hospitals, schools, dentists’ offices, shopping malls, airport terminals—without encountering hand sanitizing stations. Since the onset of the COVID-19 pandemic, public safety measures have introduced a plethora of requirements, including providing hand sanitizer to occupants where hand washing may not be available or as an extra safety measure, in order to protect communities from the spread of the virus. To meet health and safety requirements, facilities are stocking up on hand sanitizer products, and in many cases are using and storing more than they ever have before.

Many safety professionals may not realize it, but NFPA 101®, Life Safety Code®, as well as NFPA 1, Fire Code, regulate the use of alcohol-based hand rub (ABHR) in most occupancies. When the subject entered the 2006 edition of the Life Safety Code, provisions for this equipment were only found in the chapters for health care and ambulatory health care occupancies. One edition later, in 2009, the requirements were expanded and added to the chapters for educational as well as daycare occupancies. For the 2018 edition, a set of provisions outlining the protection criteria for the use of alcohol-based hand sanitizers was added to Chapter 8, mandating compliance with it for any occupancy chapter that chose to reference it to safely permit the use of ABHR dispensers.

The requirements currently address alcohol-based hand rub sanitizing liquids and aerosols. Expansion of this provision to all occupancies, if permitted by reference, recognized the need for a set of safe regulations for use in any building as the prevalence of the ABHR dispensers had grown substantially and the need for these safety criteria might be more necessary today than ever before.

But why, among other fundamental fire and life safety issues, do the codes go into the details of regulating a component as small as an ABHR dispenser? Many commonly found ABHR solutions are classified as flammable liquids and can release ignitable vapors at room temperature and above. When exposed to an ignition source, they can ignite and cause a fire. Improper storage of flammable liquids is also a concern. Facilities today may be stockpiling ABHR solutions and storing them in locations not protected or designed to accommodate hazardous materials in such quantities. Like other hazardous materials, the codes limit the quantities of these materials both in use and in storage and include restrictions on the locations of dispensers containing the liquid. The total quantities of flammable liquids in any area should comply with the provisions of other recognized codes, including NFPA 1 and NFPA 30, Flammable and Combustible Liquids Code.

In addition to limitations on the volume of ABHR in storage, as well as limitations for quantities in use per smoke or fire compartment, NFPA 101 also includes criteria specific to protecting occupants from fire. The capacity of each dispenser, for example, is restricted in order to limit the amount of product in use. Most individual dispensers cannot exceed .53 gallons (2.0 L), less if the dispenser is located in a corridor or space open to a corridor. That means a gallon container of ABHR with a pump to dispense the liquid, a common hand-sanitizer setup the moment, exceeds the maximum capacity. It should also be noted that educational occupancies do not permit ABHR dispensers in corridors or spaces open to corridors. While most occupancies provide a simple reference to the core set of provisions in the code, educational occupancies retain their own list, which differs by this one criteria that limits the location of ABHR dispensers in corridors. This is also likely a very common violation during this time as schools are being asked to provide hand sanitizer is so many locations throughout the building.

Dispensers are required to be separated from each other by at least 4 feet of horizontal spacing. This limits the probability that a fire could spread from dispenser to dispenser. Dispensers also cannot be installed within specific distances above, to the side of, or below an ignition source. Dispensers can be installed above carpeted floors only where the area of the building is sprinklered. This limits the potential for combustible floor covering to contribute to the fuel load and fire growth should ABHR that may have leaked or pooled on the floor ignite. Finally, the code provides a detailed requirement mandating the specific operation of the dispensers. Ensuring proper operation, whether manual or automatic activation, reduces the likelihood that extra solution will leak and form a pool of flammable liquid on the floor below.

As these points demonstrate, the issues related to ABHR extend well beyond the storage and protection of large amounts of the liquid. Safety professionals also need to understand the life-safety requirements related to hand sanitizer and dispensers, especially considering the potentially long-term nature of the current pandemic.

Kristin Bigda is technical lead for Engineering Technical Services at NFPA. NFPA members and AHJs can use the Technical Questions tab to post queries on NFPA 101 at To follow the progress on the upcoming edition of the code, visit Top photograph: Getty Images