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.

Brad Keyes
Brad Keyes, CHSP

Brad is a former advisor to Healthcare Facilities Accreditation Program (HFAP) and former Joint Commission LS surveyor. He guides clients through  organizational assessment; management training; ongoing coaching of task groups; and extensive one-on-one coaching of facility leaders. He analyzes and develops leadership effectiveness and efficiency in work processes, focusing on assessing an organization’s preparedness for a survey, evaluating processes in achieving preparedness, and guiding organizations toward compliance. 

As a presenter at national seminars, regional conferences, and audio conferences, Brad teaches the Keyes Life Safety Boot Camp series to various groups and organizations. He is the author or co-author of many HCPro books, including the best-selling  Analyzing the Hospital Life Safety Survey, now in its 3rd edition. Brad has also authored a variety of articles in numerous publications addressing features of life safety and fire protection, as well as white papers and articles on the Building Maintenance Program. Currently serving as the contributing editor of the monthly HCPro newsletter Healthcare Life Safety Compliance  gives Brad further insight into the industry’s trends and best practices.