by Brad Keyes, CHSP, on Mar 18, 2019 1:00:58 AM
Q: In a business occupancy building, can alcohol based hand-rub dispensers be placed over carpeted area with no sprinklers?
A: Maybe yes and maybe no… It all depends on which AHJ is looking at your business occupancy.
Section 184.108.40.206 (8) of the 2012 LSC requires ABHR dispensers that are mounted over carpets, to only be in sprinklered smoke compartments. But this only applies to healthcare occupancies, and section 220.127.116.11 has similar language for ambulatory healthcare occupancies. The problem is, there is nothing written in chapters 38 or 39 regarding the installation of ABHR dispensers in business occupancies.
Since nothing is written in the business occupancy chapters, one may think there are no limitations, and the ABHR dispensers may be placed wherever you want without regard to regulations. Some AHJs may agree, and allow the ABHR dispensers be installed over carpet in an unsprinklered area. But the AHJs with healthcare experience and knowledge probably will not, based on their understanding of chapters 19 and 21. And, this is not an incorrect process, since they know these regulations regarding ABHR dispensers and can apply them to a business occupancy based on safety-related issues. Section 18.104.22.168 supports this concept.
But please understand, section 22.214.171.124 of the 2012 LSC prohibits the handling and storage of flammable liquids where it would jeopardize egress. This means ABHR dispensers are not permitted in egress corridor. Chapter 18/19 and 20/21 specifically permit ABHR dispensers in corridor so that over-rides section 126.96.36.199. But the business occupancy chapters 38 and 39 do not have this language to over-ride 188.8.131.52, so that means ABHR dispensers are not permitted in egress corridor of business occupancies.
My advice is follow the same regulations for ABHR dispensers found in 184.108.40.206 for business occupancies, with the exception that ABHR dispensers are not permitted in egress corridors of business occupancies.