Christmas Garland

Q: We are a fully sprinkled hospital. Is it permissible to hang Christmas garland from the ceiling, as long as we stay away from sprinkler heads and abide by the 30% rule? Does the garland need to be fire-retardant?

A: According to section 19.7.5.6 (4) of the 2012 Life Safety Code, combustible decorations such as photographs, paintings, and other art are permitted as long as they are attached directly to the walls, ceiling, and non-fire-rated doors provided the following is complied with:

  • Decorations on non-fire-rated doors not interfere with the operation of any required latching of the door;
  • Decorations do not exceed 20% of the wall, ceiling and door areas inside any room or space of a smoke compartment that is not protected with sprinklers;
  • Decorations do not exceed 30% of the wall, ceiling and door areas inside any room or space of a smoke compartment that is protected with sprinklers;
  • Decorations do not exceed 50% of the wall, ceiling and door areas inside patient sleeping rooms having a capacity not exceeding four persons in a smoke compartment that is protected with sprinklers;

According to the Annex section A.19.7.5.6 (4):

  • The percentage of decorations should be measured against the area of any wall or ceiling where the decorations are located, and not the aggregate total of all walls, ceilings, and doors;
  • The decorations must be located such that they do not interfere with the operation of any doors, sprinkler, smoke detector, or any other life safety equipment;
  • The term “Other art” might include hanging objects or three-dimensional items.

While the Annex section of the Life Safety Code is not considered to be part of the requirements of the enforceable code, it is considered explanatory material intended for informational purposes only. It provides guidance to the readers of the LSC on what the reasoning was by the Technical Committee when that section of the code was written. Most authorities having jurisdiction (AHJ) follow what the Annex says but they are not under any obligation to do so.

So, let’s break this down into steps:

  1. Garland is not the same as a photograph or a painting, but may likely comply with the definition of ‘Other art’ as explained in the Annex.
  2. Some surveyors may believe that garland that is suspended from the ceiling and allowed to ‘droop’ may be considered to not be attached directly to the ceiling as section 19.7.5.6 (4) requires.
  3. Non-fire-retardant garland attached directly to the ceiling appears to be permitted based on what the Annex says, provided it does not take up more than 30% of the ceiling space from which it is attached.
  4. The garland cannot interfere with the sprinklers so you would have to comply with section 8.6.5.1.2 and 8.6.5.2.1.3 of NFPA 13-2010 for ceiling mounted obstructions. Quite honestly, this will be pretty difficult to meet with hanging garland in a corridor.

The problem with all of this is not every surveyor will agree that garland qualifies as ‘Other art’. You can show them what the Annex says, but remember that they are not under any obligation to comply with what the Annex says. Most AHJs do, but you may get a rouge surveyor who simply does not agree and will cite it if they observe it. And, as stated above, it is very challenging to suspend something like garland from the ceiling in a corridor and not interfere with the sprinklers. Make sure you follow NFPA 13-2010 carefully.

All in all, it would be easier to not permit it in your facility.

Patient Therapy Artwork: Decorations vs. Communication

Q: You once said this regarding bulletin board decorations:

If the bulletin board is decorated then yes; it is counted as decorations. But if the bulletin board is simply communication documents, then they are not decorations (even if they are combustible) and they are not counted in the wall surface calculations for decorations.

I would like to add a twist to this topic. We are a psychiatric hospital and the patients use a therapy activity for painting or drawing. They like to post their art work on the wall of the day-room with scotch tape. I interpret their art as a function of the hospital and as form of therapy and communication. I do not consider it decorations. Does this change your answer?

A: No. If I was surveying and saw what you described, I would still be inclined to consider the patient therapy artwork as decorations. Now, if you have documentation from medical and clinical experts in the form of a policy that confirms the patient therapy artwork is not decoration, but a clinical form of communication, I wound yield to those subject matter experts on this issue, and allow it to be communication.

But with the changes in the 2012 LSC on what they consider decorations, as long as you don’t exceed the 20% or 30% surface area of the walls and ceilings, I don’t think it will be a problem.

Christmas Decorations – Part 2

Q: I enjoyed your recent post regarding Christmas decorations. However, can you please simplify for me the rules on Christmas decorations in hospitals? The percentages are a little confusing, I think. Thank you very much.

A: Not to be a smarty-pants, but here is a simple interpretation:

DON’T ALLOW ANY DECORATIONS!

I know that would not be very popular, but that would be the safest and easiest. But here is another way of looking at decorations:

  • If your building is fully sprinklered, the LSC permits up to 30% of the walls and ceilings to be covered with combustible decorations.
  • Combustible decorations that are not mounted to the walls or ceilings are not permitted (i.e. Christmas trees)
  • Decorations that are not attached to the walls or ceilings must be flame retardant
  • NFPA 70-2011, Article 590.3(B) does permit UL listed extension cords to be used on holiday decorations for up to 90-days.
  • All electrical decorations must be UL listed

Christmas Decorations

Q: I notified our administration that Christmas decorations are basically forbidden in a healthcare occupancy. We do have a few floors that are business occupancy and they were wondering what the restrictions of decorating are within a business occupancy (we are fully sprinkled). I do not see anything about this in the Life Safety Code pertaining to business or mixed occupancy. Do you mind sharing any advice?

A: Well…. Actually, the Life Safety Code does address this issue and there is a difference between occupancies. Section 19.7.5.6 of the 2012 LSC prohibits combustible decorations in a Healthcare Occupancy (i.e. hospital), with the exception (and this is a rather generous exception) of wall and/or ceiling mounted combustible decorations that cover 20% of the wall and ceiling surface in non-sprinklered smoke compartments, 30% of the wall and ceiling surface in a sprinklered smoke compartment, and 50% of the wall and ceiling surface in patient sleeping rooms that have a capacity of no more than 4 persons in smoke compartments that are full protected with sprinklers.

In chapter 39 for Business Occupancies, there are no restrictions, so decorations are not restricted. However, you cannot have non-UL listed electrical decorations, and the National Electrical Code prevents you from using extension cords to power electrical decorations.

Patient Room Decorations

Q: Where does “Homelike Environment” end and fire safety begin? We have a resident who likes to push-pin everything she makes in activities to her wall. On a recent Life/Safety visit, the surveyor noted that she had “too much stuff” on her walls and that it was a “fire hazard”. We are supposed to encourage “homelike” and “Individualized Care”, then we are told that we have to tell the resident that they cannot decorate their “home” as they desire. I know there has to be a balance, but the items do not impede entrance nor egress to the room and, while there are a lot of items, high and low, they are not on top of one another nor sticking out more than 3 or 4 inches from the wall. One might consider them to be “cluttered”, however, they are not on the floor. Also, he said that everything from pictures to wreaths to whatever has to be “flame retardant”. Are we to spray everything that a family brings in from home?

A: By the sound of your comments, it appears to me that you are referring to a nursing home environment. I am very empathetic to your problem as I understand that CMS state agencies want you to create a “home-like” environment for long-term care patients, but yet, you are required to comply with the 2012 edition of the Life Safety Code.

However, there is some relief available to you on this subject. Since CMS adopted the 2012 edition of the Life Safety Code effective July 5, 2016, section 19.7.5.6 changes how decorations may be displayed in the patient’s room:

  • Combustible decorations are permitted to be attached to walls, ceiling and non-fire rated doors as long as the decorations do not interfere with the operation of the doors
  • Combustible decorations may not exceed 20 percent of the wall, door and ceiling areas inside any room or space of a smoke compartment that is not fully protected by sprinklers
  • Combustible decorations may not exceed 30 percent of the wall, door and ceiling areas inside any room or space of a smoke compartment that is fully protected by sprinklers
  • Combustible decorations may not exceed 50 percent of the wall, door and ceiling areas inside patient sleeping rooms having a capacity of no more than 4 patients, in a smoke compartment that is fully protected by sprinklers

I don’t know if the decorations covering the walls that the surveyor saw were within the above limitations, but I would think your organization could calculate the square footage of the decorations and ensure it stays within the limits.

Office Door Holiday Decorations

Q: Staff members at our behavioral healthcare facility enjoy decorating their corridor office doors (business occupancy, 20-minute fire-rated doors, multiple floors) with wrapping paper, bows, etc. affixed with scotch tape for the holidays. Are there specific prohibitions against this? We don’t want to be a Grinch unless necessary. thanks!

A: Section 7.1.10.2.1 of the 2012 LSC says decorations cannot obstruct the function of the door or the visibility of the egress components. So, the decorations cannot obstruct the door in any way.

Section 4.1.4.1 of NFPA 80-2010 says signage on fire-rated doors cannot be more than 5% of the door surface. Now decorations may not be considered signage by most individuals, but the intent is to keep the fire-load on the door to a minimum so it can function properly in the event of a fire. I can see where a surveyor would have a serious issue with decorating fire-rated doors with wrapping paper and bows, because it adds fuel to the door that was not present during the UL testing of the doors.

Sorry, but I suggest you be the Grinch and tell them to remove wrapping paper and bows from the fire-rated doors.

Holiday Lights

Q: What (if any) is the regulation on the governance of holiday lights in a healthcare occupancy?

A: Section 19.7.5.6 of the 2012 LSC only address combustible decorations, and does not address holiday lights. You didn’t say but it is presumed that the holiday lights are not combustible. The Life Safety Code does not address electrical decorations. However, the 2012 Life Safety Code does say under section 4.6.1.2 that any requirements that are essential for the safety of building occupants and that are not specifically provided for by this Code shall be determined by the authority having jurisdiction.

Your accreditation organization and likely your state agency that surveys on behalf of CMS, have standards that address electrical safety, or building safety. If you use holiday lights in an unsafe manner, then a surveyor can cite you for non-compliance with their general safety standards.

Often times these AHJs will expect you to have a policy on the safe use of holiday lights in your facility, that way they can hold you accountable to what your policy says. So if you have a policy on how you expect your staff to use holiday lights, then that will likely suffice.

Combustible Decorations

Q: Must combustible decorations have a flame-retardant coating and sticker affixed (or documentation provided) as long as the total area does not exceed the 30% wall surface threshold for fully-sprinklered smoke compartments?

A: According to 19.7.5.6 of the 2012 LSC, combustible decorations are prohibited in healthcare occupancies unless they meet one of the 5 listed criteria. The 30% wall and ceiling allowance is one of those five exceptions. So, no; the combustible decorations do not have to be flame retardant or a sticker affixed as long as the total area does not exceed the 30% for fully sprinkler smoke compartment.

Combustible Decorations

Q: We have a large wall 15 ft. x 12 ft. in our public cafeteria in the hospital that gets decorated with a different theme every quarter. This was started early this year and everyone seems to love it. Materials used varies from papers, pictures, plastics, cardboard, etc. Should this be a concern or a violation of the Life Safety Code?

A: Yes… it should be a concern. Section 19.7.5.6 of the 2012 LSC discusses the limitations of combustible decorations on wall and ceiling surfaces. You are only allowed to cover 20% of the wall surface in non-sprinklered areas, and only 30% in sprinklered areas. Keep an eye on the quantity of wall surface covered to make sure they do not cover more than the allowed amount.

Combustible Decorations

images[5]Combustible decorations have been prohibited in healthcare occupancies (i.e. hospitals, nursing homes) for decades; however decorations that are flame-retardant are permitted, according to section 19.7.5.4 of the 2000 Life Safety Code. But managing decorations and keeping track of the flame-retardant documentation can be a challenge for most facility managers.

Staff like to brighten their office or work environment by bringing in decorations they find from home. Unfortunately, these decorations often times do not meet the requirements for fire-retardant, as required by the Life Safety Code. But even flame-retardant decorations can get you in trouble as mentioned in the following note I received from Chip Hicks, the safety officer for Baptist Health System in Montgomery, AL.

Brad: I want to share a recent Joint Commission survey experience. We have a three hospital system with a pretty robust decorating policy. With that said we were surveyed last week and during the LS/EC building tour the LS specialist came across some decorations in one of our units. He asked for clarification on combustibility which we provided. After looking at the documentation he asked me to remove some of the material, find him a lighter and a place outside to perform a test. We went outside and tried to light the decorations and to my surprise both pieces of material erupted in flames. One piece burned so quickly I had to drop it to keep from burning myself. Anyway, I just wanted to share that surveyors are looking more closely at decorations and performing these tests. Frankly I’m glad he did as it was an eye opener for me and I will no longer trust any flame retardant or flame resistant documentation. As you can imagine we are in the midst of evaluating our decorating policy.

When I was a surveyor for Joint Commission, we were not permitted to conduct such tests, due to the liability involved. Who knows what fires I could have started with a simple decoration test? I suspect the official position of the accreditor is they still do not permit them, but when the surveyor is onsite and wants to do a test like that… who’s going to stop him?

As Chip mentioned, he was glad that the surveyor brought to his attention the combustibility of “flame retardant” decorations.