Carbon Monoxide Alarm Requirements for Maryland Hotels and Short-Term Rentals

Maryland requires carbon monoxide alarms in all hotels, lodging houses, and rental dwelling units under Public Safety Article, Title 12, Subtitle 11 (§§ 12-1101 through 12-1106). The mandate was significantly expanded by Chapter 175 of 2016 (HB 849), which extended CO alarm requirements from newly constructed homes to existing hotels and rental properties statewide. Hotels and lodging houses must install CO alarms in any guest room that contains a CO-emitting device, is adjacent to such a room or an enclosed unventilated attached garage, or is connected by ductwork to those spaces. The compliance deadline for hotels and lodging houses was April 1, 2017. Short-term rental properties not meeting the hotel threshold are covered as rental dwelling units under § 12-1104(c), with a compliance deadline of April 1, 2018. Enforcement falls to the Maryland Office of the State Fire Marshal and local fire officials under COMAR 29.06.01 and Public Safety Article Title 6.

Hotels, defined under Public Safety Article § 9-201(d) as buildings with more than 16 sleeping accommodations under the same management used primarily by transients, must comply under § 12-1104(b). Lodging or rooming houses, defined under § 9-201(e) as buildings providing accommodations for 16 or fewer individuals on a daily or weekly basis, are subject to the same requirement. Together, these definitions cover commercial transient lodging of any size. Short-term rental properties that do not meet the hotel or lodging house threshold are covered as rental dwelling units under § 12-1104(c). Maryland has no statewide STR licensing program; STR operators are subject to the rental dwelling unit provisions of the CO alarm statute regardless of local licensing status.

Hotel and lodging house operators must install a CO alarm on the wall inside each guest room that: contains a device emitting carbon monoxide; is adjacent to a room or area containing such a device; is adjacent to an enclosed, unventilated, attached garage; or is connected by ductwork to a garage or to a room or area with a CO-emitting device. The statute's own words are "on the wall inside each guest room", which settles a question most states leave to a code section: Maryland does not offer a corridor option for a covered room. An additional alarm is required in each mechanical room or area containing or adjacent to CO-emitting equipment, under Public Safety Article § 12-1104(b). An alternative placement rule under § 12-1104(d) allows operators who install a centralized CO alarm system capable of emitting a distinct audible warning to all occupants to instead place alarms within 25 feet of any CO-producing fixture or equipment.

Hotels and lodging houses may choose from three power-source options: AC hardwired with secondary battery backup; a sealed, tamper-resistant, battery-powered alarm with a minimum 10-year battery life; or an alarm connected to an on-site monitored control unit that notifies a responsible party upon activation. Under § 12-1105, no person may render a required CO alarm inoperable. Rental dwelling unit operators, including STR hosts, must install CO alarms outside each sleeping area and on every level of the dwelling including the basement, under § 12-1104(c), with a compliance deadline of April 1, 2018.

CO alarms in Maryland must be listed by a nationally recognized testing laboratory approved by the Office of the State Fire Marshal under Public Safety Article § 12-1101(b), in practice, UL 2034 for standalone alarms. Installation must comply with the manufacturer's instructions and NFPA 720 standards incorporated by reference through the State Fire Prevention Code. Combination CO and smoke alarms are permitted under § 12-1103, provided they also meet applicable smoke alarm listing requirements.

For hotel and lodging house properties, placement is proximity-based: alarms are required only in rooms with or adjacent to CO-producing equipment, or connected by ductwork to such spaces, and in mechanical rooms. Rental dwelling units require alarms outside each sleeping area and on every level including the basement. For hotels with a centralized alarm system, alarms may instead be placed within 25 feet of any CO-producing fixture. The statute does not specify a mandatory testing interval at the statutory level.

The Maryland Office of the State Fire Marshal enforces CO alarm requirements under COMAR 29.06.01 and Public Safety Article Title 6, Subtitle 3. County and municipal fire marshals operating as deputized agents of the State Fire Marshal under § 6-304 conduct enforcement at the local level. Hotels are generally subject to annual inspections as high-occupancy buildings. The State Fire Marshal may enter buildings at reasonable hours without prior notice to conduct inspections under § 6-307; administrative search warrants are available if access is denied. Baltimore City operates under a separate enforcement regime and maintains independent fire code enforcement through its own fire marshal's office under COMAR 29.06.01.03(C).

Violations of the State Fire Prevention Code's CO alarm requirements are prosecuted as misdemeanors under Public Safety Article § 6-601, carrying a fine of up to $1,000, imprisonment of up to 10 days, or both. Under § 6-317, each day a fire-hazard violation continues after the owner has knowledge or receives official notice constitutes a separate offense, creating exposure of up to $1,000 per day of continuing noncompliance. The State Fire Marshal may also issue abatement orders under §§ 6-318 through 6-321; failure to comply may trigger additional criminal enforcement.