Ministry of the
Solicitor General

Use of Alcohol-Based Hand Sanitizer in Schools

Communiqué du commissaire des incendies

Use of Alcohol-Based Hand Sanitizer in Schools

Communiqué 2021-08

August 4, 2021

This communiqué replaces Fire Marshal’s Communiqué 2020-16, issued on September 10, 2020 which is now rescinded.

This communiqué updates the link to the Ministry of Education’s Guide to re-opening Ontario’s schools and expands on the first safe practice for the use of alcohol-based hand sanitizer in schools.

The use of alcohol-based hand sanitizer has become a common method to combat the spread of viruses and is identified as a strategy for maintaining hand hygiene for staff and students in response to COVID-19 in the Guide to re-opening Ontario's schools. With the use of hand sanitizer becoming more widespread, compliance with Fire Code requirements and the adoption of safe practices are key to maintaining fire safety in schools.

Hand sanitizers contain various active ingredients and are typically categorized as either alcohol-based or non-alcohol-based products. Hand sanitizer products typically recommended in preventing the spread of COVID-19 are those with 60 per cent to 90 per cent alcohol. Due to their high concentration of alcohol, these products may be classified as flammable liquids, as defined in Article 1.4.1.2. of Division A of the Ontario Fire Code (Ontario Regulation 213/07, as amended). To determine classification of a hand sanitizer product, refer to the product (Material) Safety Data Sheet.

Where a hand sanitizer meets the classification of a flammable liquid, storage, handling and use in schools are subject to the requirements of Sections 4.1 and 4.2 of Division B of the Fire Code. Examples of provisions in Section 4.1 that may apply include ratings for portable fire extinguishers, control of ignition sources, spill control measures, ventilation requirements, and fire safety plan changes to address storage, use and dispensing of product. While Section 4.2 includes additional requirements such as maximum quantities and storage locations, a hand sanitizer as a pharmaceutical product may be exempt from many of these requirements when used and stored in small quantities. Fire departments are encouraged to work together with school administrators to consider implementing additional safe practices to further minimize fire risk in school settings. Some examples of safe practices for the use of alcohol-based hand sanitizers in schools are included below.

For assistance with evaluating options to address fire safety, please contact your local fire protection adviser.

Safe Practices for the Use of Alcohol-Based Hand Sanitizer in Schools

  1. Sources of Ignition

Exercise caution when using hand sanitizer. Read and follow product warning labels. Avoid exposure to open flames and other heat sources. When using hand sanitizer, rub hands together until they are completely dry and exercise caution in areas where open flames or other sources of heat may be present. In a school setting, this includes hazardous classrooms such as science laboratories and shop classes. In these areas, consider alternate methods of hand washing. Hand sanitizer, containing a high concentration of alcohol, is flammable and may emit vapours that could ignite if exposed to an ignition source.

  1. Spacing

Maintain a minimum 1.2 m horizontal centre to centre spacing between dispensers where more than one dispenser is provided, such as in a corridor.

  1. Quantity in Rooms and Corridors

Ensure the capacity of individual dispensers in corridors and classrooms does not exceed 1.2 L, with no more than one dispenser provided at each egress door or exit from a classroom.

  1. Supervised Areas

Locate dispensers in areas that are supervised to reduce the risk of misuse. This may include locations such as the school entrance where the main office is located and classrooms where school staff are typically present to observe any misuse or spillage. 

  1. Obstructions

Ensure dispensers do not obstruct the required width of a means of egress.

  1. Carpeted Areas

Avoid installation of dispensers directly over carpeted surfaces except if the floor area is sprinklered or measures are taken to control accumulation of the product in the carpet. 

  1. Excess Stock

Store excess stock of hand sanitizer in accordance with Fire Code requirements where applicable. As the quantities outlined in the Fire Code are not specific to hand sanitizer products, the presence of any other flammable and combustible liquids must also be taken into consideration when assessing total volume. 

  1. Dispenser Operation

Test dispensers according to manufacturer’s instructions after each refill and limit the quantity of product dispensed upon activation to the required amount as specified by the manufacturer. Regularly check dispensers to ensure they are maintained in operating condition and are not activated accidentally or maliciously. Clean spilled / residual hand sanitizer product to prevent accumulation. 

  1. Fire Safety Plan

Review and update the school fire safety plan to conform with Fire Code requirements to reflect fire safety procedures that may be required as a result of the use and storage of hand sanitizer products. Depending on volume of product being stored, procedures may be required to address items such as the control of fire hazards and product spills.  

  1. Disposal

Immediately dispose of empty hand sanitizer containers in a non-combustible receptacle and, on a daily basis, move waste to an outdoor receptacle to prevent accumulation. 

For additional information, see OFM-TG-02-2011 Safe Practices for the Use of Alcohol-Based Hand Rub.