2012 NFPA 101 Life Safety Code, – Section 11 - Operation of the Dispenser: Language Stirring Ambiguity Surrounding use of Aerosol Cans

Discussion created by mary.pick on May 9, 2017
Latest reply on May 11, 2017 by rfdacm02

As an organization, we understand the code pertaining to dispensers and placement of alcohol-based hand rubs.  What is creating a bit of controversy is Section 11.  We are hoping to reach out to colleagues who might offer an opinion(s) of how ‘aerosol’ alcohol-based hand rub dispenser/holders meet NFPA LSC compliance criteria, specific to clauses 11 (d) and 11 (e ) below.


Operation of alcohol-based aerosol cans:  Most of us know that alcohol based hand rubs that are packaged in an aerosol can are either placed into a dispenser/holder mounted to a wall or can be placed on a counter and manually dispensed when needed.  These aerosol cans look like and dispense the same as an aerosol can of personal care hair mousse.  As the nozzle on an aerosol alcohol-based hand rub or personal care hair mousse can is manually pushed, product is dispensed.  So, the ambiguity:  It’s well known that as long as the nozzle valve remains pressed open manually by hands, product will continuously flow out of the aerosol can.  


Controversy scenario of alcohol-based aerosol cans that is causing confusion:  Therefore, no matter what the product label states for directions of use, if someone decides to (intentionally or unintentionally) continuously press the nozzle, a constant flow of product will be delivered out of the can, which could be viewed differently, making the technical provisional clauses of the NFPA code 11 (d) and 11 (e ) be interpreted in different ways such as not meeting label instructions and being malicious. (11):  Operation of the dispenser shall comply with the following criteria:

11 (d).   The dispenser shall not dispense more solution than the amount required for hand hygiene consistent with label instructions.

11 (e).   The dispenser shall be designed, constructed and operated in a manner that ensures accidental or malicious activation of the dispensing device is minimized.


Have others ran into this debate and how are you interpreting these two clauses, specific to aerosol cans, given the controversy scenario above?  


How do we get clarity of aerosol cans to meet compliance criteria, prior to an inspector showing up, around these two technical provisional clauses of the NFPA code?