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Ho-ho-ho-hope your decorations are safe!
By Doug Beardsley | December 4, 2020 | All providers
You’ve made it past the pumpkins, turkeys, and fall-themed décor…meaning your staff, clients, and family members have been busy decorating for Christmas, Hanukkah, New Years, etc. While holiday décor may look festive and help to create a “homey” atmosphere, they may also cause a skilled nursing facility (SNF) or nursing facility (NF) to be in violation of the Life Safety Code and could place your residents and staff in harm’s way. Housing with Services establishments should check with their local building authorities to determine if decorating limitations are in place for their building type.
The Centers for Medicare & Medicaid Services (CMS), as well as the Minnesota Department of Health (MDH) and the Minnesota State Fire Marshal Division require that nursing facility decorations meet minimum levels of fire safety as required by the National Fire Protection Association (NFPA) 2012 Life Safety Code adopted by CMS. While these regulations and codes apply specifically to certified nursing facilities, caution should also be used by housing providers to maintain a fire-safe environment.
Christmas, Hanukkah, New Years, and other holidays are wonderful times for staff and residents to decorate their facility and resident rooms to be more festive and seasonal. However, many decorations are prohibited for use in the SNF/NF. Compliance with these requirements may cause you to be viewed as a Grinch, but safety should always come first!
Use the following as guidelines when decorating your facility and resident rooms:
Decorations shall not be combustible
No combustible or highly flammable decorations are allowed: Combustible decorations shall be prohibited in any healthcare occupancy unless they are flame-retardant. Straw, hay, dried cornstalks and cut greenery (evergreen wreaths and “live” Christmas trees) fall into this combustible category. CMS is not aware of any type of treatment that would change the classification of these items to non-combustible. You also do not want to have these items placed too close to the exterior walls of your building—fires have occurred under canopies and even in landscaping wood chips from carelessly discarded cigarettes, for example. Living greenery, such as potted plants (including Norfolk Pines), are allowed.
In addition, The Minnesota State Fire Code (MSFC), Section 804.1.1, prohibits the use of natural or resin-bearing trees (Christmas trees) in health care occupancies.
The MSFC Section 804.1.1.1, does allow the use or display of flame-retardant artificial trees with listed electric light decorations in all types of occupancies, but remember that the use of extension cords is prohibited. Documentation regarding the flame-retardant ratings of such items is recommended.
However…remember that with the implementation of the 2012 version of the Life Safety Code, combustible decorations continue to be prohibited in any health care occupancy, unless one of the following criteria is met:
(1) They are flame-retardant or are treated with approved fire-retardant coating that is listed and labeled for application to the material to which it is applied. (note—this is similar to the 2000 code requirement)
(2) The decorations meet the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (note—this a new option under the 2012 edition of the code)
(3) The decorations exhibit a heat release rate not exceeding 100kW when tested in accordance with FNPA 289, Standard Method of Fire Test for Individual Fuel Packages, using the 20 kW ignition source. (note—this a new option under the 2012 edition of the code)
(4) The decorations, such as photographs, paintings, and other art, are attached directly to the walls, ceiling, and non-fire-rated doors in accordance with the following: (note—this a new option under the 2012 edition of the code)
(a) Decorations on non-fire-rated doors do not interfere with the operations or any required latching of the door and do not exceed the area limitations of 18.7.5.6 (b), (c), or (d) below.
(b) Decorations do not exceed 20 percent of the wall ceiling, and door areas inside any room or space of a smoke compartment that is not protected throughout by an approved automatic sprinkler system.
(c) Decorations do not exceed 30 percent of the wall, ceiling, and door areas inside any room or space of a smoke compartment that is protected throughout by an approved supervised automatic sprinkler system.
(d) Decorations do not exceed 50 percent 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 throughout by an approved supervised automatic sprinkler system.
In addition, the following restrictions also apply to decorations:
- The path of egress shall always be maintained clear and unobstructed
- Fire protection equipment should always be clear and unobstructed. Nothing shall be within 18 inches from the bottom of the sprinkler head.
- Nothing shall block the visibility of, or be hung from, any fire protection equipment including sprinkler heads and piping, smoke detectors, fire alarm horns & strobes, pull stations, fire extinguishers, emergency lighting or exit signage.
- Extension cords and flexible cords shall not be a substitute for permanent indoor wiring. Surge protectors (known in the Fire Code world as “relocatable power taps”) can be used as long as they are plugged directly into a wall receptacle, are of the polarized or grounded type, are equipped with overcurrent protection, are not used in a manner that they extend through walls, ceilings, floors under doors, etc., and are not used beyond the electrical capacity they are designed for. The use of either extension cords or relocatable power taps is strongly discouraged for both fire-safety reasons and because they tend to create tripping hazards for both staff and residents.
If in doubt regarding decorations, please give your local fire authority a call.
There are many ways to create a festive and seasonal “look” to your facility without violating any of these requirements. Please share these rules with staff, volunteers, residents, and family members who might be involved in decorating your facility or resident rooms. Remember—the reason for these codes is safety!
Doug Beardsley | Vice President of Member Services | dbeardsl@careproviders.org | 952-851-2489