Large Trash Containers

Q: I have a question about the limits on the size of trash containers in healthcare facilities, including ambulatory healthcare facilities. Consider larger collection bins, that are housed in one-hour rated soiled utility rooms, and are then moved close to the loading dock area, an area which is separated from the rest of the facility with 2-hour occupancy separations and is indicated “Business” occupancy although it is the sub-basement of a hospital building. These are staged in a hallway of this business area while awaiting emptying, cleaning and return to the soiled utility rooms. NFPA 101 2012 Chapter 38/39.7.6 would seem to permit this. What do you think?

A: You are correct… As long as the large tubs are located in business occupancies, there is no Life Safety Code requirement that requires them to be stored in a 1-hour hazardous room. That is strictly a healthcare occupancy (see of the 2012 LSC) and an ambulatory healthcare occupancy (see of the 2012 LSC) requirement.

Trash Cans

Q: Can you tell me where to find the code reference for trash cans in healthcare, ambulatory, and business occupancies? I have reviewed the respective chapters in the 2012 LSC and there does not appear to be any requirements for a rating or type of trash container to be used. I was thinking that they all had to be UL listed?

A: You are correct in that there is no mention of trash can ratings in the Life Safety Code… That is because there are none. Years ago (perhaps 25 years ago) there used to be, but the requirements for a trash can to have a specific rating has since been deleted.

Now, there is a requirement for containers holding clean waste and documents waiting for shredding to be FM Approval 6921 (See of the 2012 Life Safety Code), but other than that there are no requirements.

Trash Containers with Lids?

imagesOMMZ5LLSAn off-site clinic far from the main hospital will be part of the accreditation survey. Currently they have open trash cans (wastebaskets) throughout the building. The staff at the offsite locations has been told that they need to replace all these open trash cans with trash cans that have lids. They were told this was a requirement by the accreditation organization. What do you say?

Be assured… there are no NFPA codes or standards that require trash receptacles with lids. If NFPA ever required it, they did away with that requirement long time ago. Likewise, there are no Physical Environment standards from the accreditation organizations that require lids on wastebaskets either.

Now, there may be Infection Control concerns for trash containers to have lids, but that would be an assessment made by the organization’s Infection Control practitioner. That may be evaluated by the surveyors, so it is suggested that the IC people address this where necessary. But there is no direct Physical Environment standard that requires lids on trash receptacle from a fire-safety stand-point.

Multiple Trash Containers

Q: We just completed a renovation of our cafeteria dining area and as part of the project an 8 container trash cabinet was built and installed in a separated area off of the dining floor. It is sprinklered and the containers are all 32 gallons. The cafeteria area is a separate smoke compartment. Is this allowed?”

A: Well, this is an interesting question. The answer is… it depends on the square footage of the trash cabinet and how it is constructed. I would say each individual 32 gallon trash container would have to be physically separated from all the others by a cabinet wall, which would create a small, individual room or area for the container. The reason for this is section of the 2000 edition of the LSC, which only allows up to 32 gallons of trash collection capacity in a given 64 square foot area. This means, if there are no physical separations between trash containers then I could see a surveyor or inspector citing you for having more than 32 gallons capacity in a given 64 square foot area. Since each individual compartment for the trash containers would presumably be less than 50 square feet in size, then you would not have any problems meeting the requirements of for hazardous areas. It is interesting to note that the exception to does allow more than 32 gallons capacity in a 64 square foot area provided the area qualifies as a hazardous area, but it is unlikely that an 8 container trash cabinet could do so. The key element in your question is the comment that the individual trash containers do not exceed 32 gallons each.

Document Shredding Containers

Q: During a recent survey, the surveyor noted that we had two 64 gallon capacity containers which we use for document shredding, sitting side-by-side in the laboratory work room. He stated we couldn’t have them in the room because they exceeded 32 gallons capacity. I was under the impression that if it was in a secured area and in a room with positive latching and sprinkled it was OK. How far off am I? What about other areas, such as medical records?

A: Section of the 2000 edition of the LSC says trash containers greater than 32 gallons must be stored in a hazardous room. Most authorities will consider document shredding containers to be equal to trash containers. Also, section says all laboratories that employ flammable liquids in quantities less than what would be considered severe are considered hazardous areas. So, your laboratory is already considered to be a hazardous area, and should be protected accordingly. If it is new construction (plans for construction approved by local authorities on or after March 11, 2003) it would be required to be fully protected with automatic sprinklers and be protected with 1-hour fire rated barriers. If it is existing conditions (plans for construction approved by local authorities before March 11, 2003) then it needs to be protected with automatic sprinklers or with 1-hour fire rated barriers. You are allowed to have as many 64-gallon document shredding containers in the laboratory as you would like, since the laboratory is already classified as a hazardous area. Unless there are other contributing factors, it appears to me that the surveyor is incorrect in this finding. The medical records area would have to qualify as a hazardous room in order to allow the 64 gallon containers in there. [Editor’s note: The 2012 edition of the LSC will exempt approved document shredding containers up to 96 gallons capacity from having to be stored in a hazardous room.]

Recycling Containers

Q: We have these big recycling containers mounted on wheels all over the hospital, which must have a capacity of 50 gallons each, at least. Does this container need to be placed in a “room protected as a hazardous area”?  The hospital is fully protected with sprinklers, by the way.

A:  Yes, it does. Section of the 2000 edition of the LSC says: “Soiled linen or trash collection receptacles shall not exceed 32 gallons in capacity… Mobile soiled linen or trash collection receptacles with capacities greater than 32 gallons shall be located in a room protected as a hazardous area when not attended.” The Joint Commission and CMS both interpret recycling containers as “trash containers”. So, you will have to find a suitable home that qualifies as a hazardous area for those containers, or obtain containers that do not exceed 32 gallons in capacity.

Fire Retardant Waste Containers

Q: Are waste container required to be fire retardant in hospitals? What about long term care facilities?

A: No, they are not. At one time, the Life Safety Code®  (LSC) required all waste containers to be listed (approved) by an independent testing laboratory (UL, FM, etc.), but that requirement was dropped from the LSC a few editions ago. Therefore, there is no requirement that waste containers be listed by an independent testing laboratory for anywhere in a healthcare occupancy, including hospital, and long term care facilities.

Trash Receptacles

Q: In a business occupancy (physician medical office) can waste receptacles that are used for exam room waste paper be made of plastic, or do they have to be fire retardant? Is there a container size limitation, such as smaller than 32 gallons that needs to be adhered to?

A: Yes, they can be made of plastic. The section of the LSC that governs trash receptacles for healthcare occupancies is 19.7.5. If you carry that subsection over to the business occupancy chapter, you will find that there is no requirement for trash receptacles (39.7). Therefore, if there is no requirement, then non-fire rated plastic receptacles are OK. There are no limitations on container size, as there is in healthcare occupancy.