Q&A: Mobile ABHR dispensers

Q: My question pertains to alcohol-based hand rub (ABHR) product in disposable or refillable pump bottles. These bottles are mobile and come in several sizes. Is there a requirement or an interpretation on whether these are to be secured? I tend to find these on med carts, nurse's stations and throughout the facility. Does the 48-inch horizontal distance to keep them separate apply to these or just to ones mounted? Are these portable bottles of ABHR product included in the aggregate totals per smoke compartment? 

A: There is no requirement to have pocket-size ABHR product secured. This allows the small bottles to be carried around by workers in their pockets. The 48-inch horizontal separation requirement does not apply to small bottles of ABHR product carried around in pockets. The portable movable bottles are included in the aggregate total for each smoke compartment.

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.