In the case of a commercial kitchen, compliance relies heavily on regular expert testing and cleaning of your extract systems to control levels of the fat, oil and grease, which arises from cooking and collects on the interior surfaces of the ductwork. Should you fail to ensure this regular testing and cleaning of kitchen grease extract systems, you may find that your buildings insurance cover is invalidated, and that you face further scrutiny of other aspects of your legal compliance with the Regulatory Reform (Fire Safety) Order. To avoid this, you must ensure that your extract system is compliant with the industry specification, TR19® Grease.

TR19® Grease: Fire Risk Management of Grease Accumulation within Kitchen Extraction Systems, is a specification issued by the BESA (Building & Engineering Services Association). It was developed from TR19®: Guide to Good Practice Internal Cleanliness of Ventilation Systems, the leading industry guidance document on ventilation hygiene. It provides a framework in which to control fat, oil and grease accumulation to safe levels

TR19® Grease applies to the whole of your kitchen extract system, from the canopy through the extract ductwork to where the system exits the building. Compliance with TR19® Grease should now be high on your list of fire safety measures.

The Regulatory Reform (Fire Safety) Order 2005, Fire (Scotland) Act 2005 and Fire & Rescue Services (Northern Ireland) Order 2006 are the principal fire regulations in the UK. TR19® Grease compliance is an essential element in meeting your legal responsibilities. Your appointed Responsible Person must ensure that the levels of grease inside every part of the ductwork are controlled within the tolerance levels quoted in TR19® Grease. They must also ensure that each section of ductwork is cleaned at regular intervals, in accordance with the tables laid out in the TR19® Grease specification.

Your insurer will also expect that you comply with TR19® Grease, as it significantly reduces the risk of fire in each kitchen extract system.

Kitchen extract fire safety cleaning and management is a specialist task, so you will need to employ an expert in order to achieve and maintain compliance with TR19® Grease. The specialist contractor that you appoint should have a sound reputation, and a long track record of providing excellent TR19® Grease compliant cleaning.

A wise strategy is to choose a member of the BESA, essentially one who is a member of the BESCA Vent Hygiene Elite Scheme (or VHE scheme). Swiftclean was influential in the formulation of TR/17, which preceded TR/19, and has been closely involved in developing every subsequent edition of the TR/19 guidelines, including TR19® Grease. The company is a founder member of the VHE scheme and provides expert witness services in cases of litigation over alleged non-compliance by contractors and commercial kitchen operators.

Demonstrating that you have complied with TR19® Grease may be just as important as complying, so your expert cleaning contractor should provide you with robust evidence. You should receive a ‘post clean report’ of each individual asset which your provider cleans for you.

This evidence should include before and after photographic evidence of every asset; as well as details of the cleaning methodology; before and after grease measurements; and details of any chemicals used during cleaning. Your documentation should clearly state that your ductwork is compliant, from the date that it was cleaned and must include certification through the BESCA VHE scheme.

Sometimes, after ductwork has been installed, parts of it are made inaccessible by the addition of extra walls, solid ceilings, or stairwells. Some ductwork systems also lack the access platforms which will allow cleaning technicians to work safely at height. It is very important that these problems are highlighted and reported to you. Your provider should provide you with schematic drawings to explain fully where any problems, especially non-compliant sections, are located. They should also provide you with suggestions for rectifying each issue. Quite often, these problems can be rectified by retrofitting some additional access doors. This is often the case in older systems which were designed without compliance with TR19® Grease in mind.

However, there are some problems which cannot be so easily overcome. if this is the case, your provider should explain the problem to you and make you aware of any major work needed. You should give careful consideration to the likely costs of major works as future compliance with TR19® Grease will ensure you meet the legal requirement. The implications of not rectifying such access issues and achieving compliance throughout the system should be explained to you clearly.

You must appoint a ‘Responsible person’. Their role is to ensure that you comply with the Regulatory Reform (Fire Safety) Order 2005. You should also appoint a competent, professional specialist cleaning provider with proven expertise in the management of kitchen extract system and canopy testing and cleaning – preferably a member of the VHE scheme. You should check that the post clean reports that you are given contain full documentation of the work carried out, including before and after photography, pre-cleaning grease thickness measurements, and meaningful certification and guidance on the frequency of cleaning required to keep fat, oil and grease thickness within safe levels. This will provide a robust audit trail, which you may need in order to demonstrate your compliance, safeguard your insurance and protect you against future prosecution.

To contact Swiftclean, call 0800 243 471, email axa@swiftclean.co.uk or visit www.swiftclean.co.uk.