Aerosol Can Storage

By Brad Keyes…

Q: Housekeeping products like germicidal, glass cleaner, air freshener are stored in a locked metal box on housekeeping cart. All of our stock of these and other products are stored in two large locked metal lockers. They are not fire rated cabinets. The surveyor said aerosols all have to be stored in fire rated cabinets. While they are in use while on housekeeping carts, they will have to be checked in and out daily from a fire cabinet.

The surveyor did not cite a tag or code for this he just told us we had to do it. I have searched and so much is left to interpretation I am confused on what to do. With all the changes occurring and more to come with state regulations and inspections I would like to be prepared.

A: It is safe to say that there is no NFPA standard, no CMS standard, and no accreditation standard that specifically says aerosol cans must be stored in a fire rated cabinet. However, if access to these aerosol products by unauthorized individuals is a safety risk (i.e. can children get into them) then it may be perceived as an unsafe environment and the surveyor would have a legitimate concern about them.

I suggest you go back to the surveyor and ask them why they believe the aerosol products have to be stored in a fire-rated cabinet. Ask for a specific code, standard, or regulation that they are using to make this recommendation.

Otherwise… it’s not a code violation, but a surveyor’s preference.

Parking Garage Underneath Healthcare Occupancy

Q: Can you have a parking garage under a health care occupancy/patient sleeping areas, that does not have smoke separations but does have a 2-hour fire rated barrier between the floors? This is a project in the planning stages. Currently the floor serves administrative offices and will be converted to a patient floor.

A: I am not aware of any reason in the Life Safety Code that would prevent you from having a parking garage underneath a healthcare occupancy, provided you have the proper 2-hour fire rated separation barrier. A parking garage is required to be a Storage occupancy according to 3.3.188.15 of the 2012 LSC, so there must be a 2-hour fire-rated barrier separating the parking garage and the healthcare occupancy.

Section 18.3.7.2 (5) is clear that open-air parking structures protected throughout by a sprinkler system does not have to be subdivided into two or more smoke compartments. Since it is new construction, the entire hospital, including the parking garage, would have to be fully sprinklered. Also, the parking garage would have to be the same construction type as the healthcare occupancy.

As always, check with your state and local authorities to see if they have more restrictive regulations.

Alcohol Storage

Q: A question for you about alcohol storage. If we have over 5 gallons of alcohol, 70% isopropyl rubbing alcohol in a 1-hour rated room, is that acceptable?

A: It depends what type of containers the alcohol is stored in, the capacity of the containers, the size of the room, and the location of the room. Based on the assumption that the flash point of the alcohol is 53°F and the boiling point is 181°F, the alcohol would be considered a Class IB flammable liquid, according to NFPA 30-2012, section 4.3.1.

The maximum size container is identified in Table 9.4.3 as follows:

Glass                           1-quart

Metal (not a drum)      5.3 gal

Safety Can                  5.3 gal

Metal Drum                 119 gal

Rigid Plastic                Not Permitted

Polyethylene               5.3 gal

Fiber Drum                 Not Permitted

According to 9.5.1, the maximum volume stored in a safety cabinet is 120 gallons. According to 9.6.1, the maximum allowable quantities of Class IB flammable liquid is 120 gallons per control area, which is defined as a space in a building. This would be a designated space and nothing else would be permitted to be stored in this space.

According to 9.7.2, the maximum number of control areas for Class IB flammable liquids in a building is:

1st floor:                                   4

2nd floor:                                  3

3rd through 9th floor:             2

Above 9th floor:                       1

According to 9.3.6, storage of Class IB flammable liquids is not permitted in basements, which is defined as a level having ½ or more of its area below ground level. According to 9.9.1, the fire-resistant construction rating of the control area storing Class IB flammable liquids is:

  • 1-hour fire-rated if the control area is less than or equal to 150 square feet
  • 2-hour fire-rated if the control area is more than 150 square feet but not more than 500 square feet.
  • 4-hour fire-rated if the control area is more than 500 square feet.

So, the answer to your question is yes, 5-gallons of 70% isopropyl rubbing alcohol stored in a metal can, or a safety can, or a metal drum, or a polyethylene container in a 1-hour fire-rated control room (i.e. designated storage room), that is not over 150 square feet in size, would be acceptable, provided the room is not located below ground level.