You’ve made it past the pumpkins, turkeys, and fall-themed décor . . . so it must be time to switch to  festive Christmas and other holiday decorations!  While holiday décor may look may look good, and help to create a “homey” atmosphere, it may also cause a Nursing Facility to be in violation of the Life Safety Code and could place your residents and staff in harm’s way.

The Centers for Medicare and Medicaid Services (CMS), as well as the Minnesota Department of Health 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) 2000 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, Hanukah, 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 nursing facility.  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:

1. Decorations shall not be combustible:

No combustible or highly flammable decorations are allowed:
Combustible decorations shall be prohibited in any health care occupancy unless they are flame-retardant.

Exception:  Combustible decorations, such as photographs and paintings, in such limited quantities that a hazard of fire development or spread is not present (2000 NFPA 101, 18/19.7.5.4).

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.

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.

Common decorating mistakes facilities make include “wrapping” picture frames or doors with flammable wrapping paper and ribbons to make them look like presents, hanging flammable holiday quilts on facility walls, using flammable crepe paper, using natural straw wreaths, hay bales, or straw scarecrows, and using extension cords to power holiday lights inside the facility or in resident rooms.

2. Means of egress shall always be maintained clear and unobstructed:

A path of egress must not be obstructed; the NFPA standard is:  Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency. 2000 NFPA 101, 7.1.10.1.

No decorations shall obstruct the path of egress; the NFPA standard is:  No furnishings, decorations, or other objects shall obstruct exits, access thereto, egress from, or visibility thereof. 2000 NFPA 101, 7.1.10.2.1.

Nothing shall obstruct the headroom in a path of egress; the NFPA standard is:  Means of egress shall be designed and maintained to provide headroom of not less than 7 ft 6 in with projections from the ceiling not less than 6 ft 8 in nominal height above the finished floor.  The minimum ceiling height shall be maintained for not less than two-thirds of the ceiling area of any room or space.  Headroom on stairs shall be not less than 6 ft 8 in and shall be measured vertically above a plane parallel to and tangent with the most forward projection of the stair tread.

Exception:  In existing buildings, the ceiling height shall not be less than 7 ft from the floor with no projection below a 6 ft 8 in height from the floor. 2000 NFPA 101, 7.1.5

Nothing shall project into the path of egress over 3 ½ inches from each side;
The NFPA standard is:  The width of means of egress shall be measured in the clear at the narrowest point of the exit component under consideration.

This includes equipment and decorations.

3. Fire protection equipment should always be clear and unobstructed.

Nothing shall be within 18 inches from the bottom of the sprinkler head; the NFPA standard is:  Automatic sprinkler and standpipe systems required by this Code shall be inspected, tested, and maintained in accordance with 1998 NFPA 25, per NFPA 101, 9.7.5. and 1998 NFPA 25, 5-2.1.2.

Obstructions shall not prevent sprinkler discharge from reaching the protected area.  Continuous or non-continuous obstructions that interrupt the water discharge in a horizontal plane more than 18 inches below the sprinkler deflector in a manner to limit the distribution from reaching the protected hazard shall comply with this section.

Exception:  The requirements of this section shall also apply to obstructions 18 in. or less below the sprinkler for light and ordinary hazard occupancies. per 1999 NFPA 13, 5-6.5.3.

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.

4. Extension cords and flexible cords shall not be a substitute for permanent indoor wiring.

Electrical wiring shall be in compliance with NFPA 70 and the International Fire Code (605.5).  Under certain circumstances properly maintained, properly sized for ampacity, grounded extension cords may be used for one single portable appliance, only if the appliance will be moved frequently (the cords cannot be affixed to structures, extended through walls, ceilings or floors, or under doors or floor coverings and not be subject to environmental damage or physical impact).

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.

5. 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
952.851.2489
dbeardsl@careproviders.org

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