Kitchen extract systems – demonstrating compliance
The Vent Hygiene Elite Scheme, launched by the Building Engineering Services Association, is being renamed as the Vent Hygiene Register. This move also marks a change in who can provide evidence of compliance in kitchen extract systems. Gary Nicholls, Managing Director of duct cleaning expert Swiftclean, explains how demonstrating your compliance with TR19® Grease is changing.
TR19® Grease, issued by the Building Engineering Services Association (BESA), is the leading industry document concerning the cleanliness of kitchen extract systems, and is increasingly seen not just as a hygiene requirement, but also as a key fire safety measure. As caterers will be aware, cooking inevitably gives rise to airborne fat, oil and grease (FOG) particles, which are drawn into the kitchen extract system. The extracted air will eventually be expelled to the outside of the property. However, as the air stream travels further from the heat source it will cool, and the FOG particles which it contains solidify, creating grease deposits, usually in the form of a greasy film layer on the inside surface of the ductwork.
This grease must be removed regularly, in accordance with TR19® Grease. How frequently the ductwork should be cleaned is laid out in helpful tables within the document, and regular specialist cleaning should now be a regular part of the maintenance of your premises.
For some years the BESA has strongly recommended that TR19® Grease cleaning should be carried out by a member of its Vent Hygiene Elite Scheme, who are able to provide post-clean certification. The Scheme, run under the auspices of the Building Engineering Services Competent Assessment (BESCA) has members who are thoroughly vetted to ensure that their technicians are properly trained and are competent to carry out cleaning in compliance with TR19® Grease. More recently, the BESA has stated that only members of the scheme, now renamed as the Vent Hygiene Register, will be regarded as competent or able to provide TR19® Grease compliant cleaning services. Without BESCA post-clean certification from a Register member, it will be difficult to demonstrate compliance.
Evidence of compliance is invaluable because it can offer protection to property owners and managers, who might otherwise face an accusation of negligence. Grease deposits are highly flammable. It is a common misconception that a grease layer must be very thick to provide fuel for a fire. In fact, a relatively thin film can represent a very real potential fire hazard. TR19® Grease stipulates that the grease layer should be controlled to within an average of 200 microns; which is about half the thickness of an average business card. Compliance with TR19® Grease is therefore an important part of fire safety measures and one of the obligations of the Responsible Person under The Regulatory Reform (Fire Safety) Order 2005.
Kitchen extract ductwork itself, if not regularly cleaned, can provide a channel through which fire can easily travel, using the grease layer as fuel. Through this convenient ‘chimney’ fire can spread to other parts of the property, or to neighbouring properties. Many fast-food outlets are situated below offices and apartments, and this can lead to risk of injury or worse to those working or living above. Failure to comply with TR19® Grease may, therefore, be regarded as negligence.
Negligence, or the appearance of negligence, can have serious consequences, especially in the event of a fire involving the ductwork. An accusation of negligence can result in prosecution, and a conviction can carry a custodial sentence. Using a Vent Hygiene Register member will mean that you have post-clean BESCA certification, which is widely recognised by investigators, and will provide evidence that the Responsible Person did all they could to fulfil their legal obligations.
Non-compliance also has implications for buildings insurance. Most providers now expect that the kitchen extract will be compliant with TR19® Grease, and may not pay out following a fire, if the system is found not to be compliant. Insurers too, increasingly favour using members of the Vent Hygiene Register.
Post-clean certification provides robust evidence of compliance with TR19® Grease, and that the Responsible Person has not been negligent. This protects the property manager or owner from possible prosecution, but also safeguards the building’s insurance policy.
A Vent Hygiene Register member will also be able to provide post-clean certification for ventilation systems which have been cleaned in accordance with TR19®, the sister document to TR19® Grease, which concerns hygiene in ventilation ductwork.
In future, it will be crucial that you appoint a specialist cleaning provider who is a member of the Vent Hygiene Register for your TR19® Grease compliance. In fact, this is set to become just as important as appointing a Gas Safe registered heating engineer or an LCA (Legionella Control Association) member to provide L8 Legionella control services. Some might say that this is long overdue, as fire in an extraction system can threaten life, as well as livelihoods.
