Unless grease extract systems are cleaned according to the latest HVCA standards, they are likely to be a fire risk. And powers of prosecution can be instigated, writes Richard Norman, managing director of Indepth Hygiene
When the HVCA was revising TR17 (Internal Cleanliness of Ventilation Systems) now TR19, the Regulatory Reform (Fire Safety Order) 2005 had not been approved by Parliament.
But the outline intentions of the legislation were known. At the same time, fires in grease extract ventilation systems, notably at Heathrow airport and at major hotels and several restaurants, underlined these installations as a potential source of fire danger to building occupants.
In anticipation of the legislation becoming law, the Ventilation Hygiene Group of the HVCA, which was responsible for producing TR19, thought it important to clarify what constitutes a grease extract ventilation system so there would be no doubt what has to be kept clear of any potential fire hazards - flammable grease deposits. One reason for the lack of understanding of these systems is that ducting runs from the initial point of extract, the kitchen canopy, behind walls and ceilings on its way to exhaust into the atmosphere.
As a result, many people responsible for building services are unaware of the configuration and, sometimes, its very existence. Only exceptionally has the system been inspected.
Furthermore, there are many who still think the extract system is in fact the kitchen canopy and filters. HVCA TR19 (Section 7) sets out to provide those responsible for the management of workplaces with a clear explanation of what makes up a typical grease extract system.
It further describes what levels of cleanliness should be achieved to ensure the system does not remain a potential fire hazard. Lastly, it gives guidance on the frequency of cleaning, relating it to the usage of the catering facilities to which it is invariably linked:
Heavy use (12-16h/day): three-monthly
Moderate use (6-12h/day): six-monthly
Light use (2-6h/day): 12-monthly
When the Fire Safety Order became law, clear guidance on this high-risk installation became available. This included how it should be cleaned and how often, to ensure it does not constitute a potential fire danger to building occupants.
The requirement to carry out fire risk assessments is a primary legal obligation. And failure to do so is a punishable offence under the Fire Safety Order, as a restaurant in Essex recently found out to the tune of a £25,000 fine with costs.
More worrying perhaps is that, even where fire risk assessments have been produced, there has been inertia on the part of management to act upon the findings. In the last 12 months, Indepth Hygiene's surveyors have provided reports on grease extract systems in more than 1,000 premises. In the majority of cases, sufficient grease deposits were found in the grease extract system to support a flash fire. Yet, in more than 30%, no action has been taken.
There is a further problem. Some organisations, particularly pub groups, are paying only lip service to their legal responsibilities by commissioning grease extract cleaning at prices so low systems are only being cleaned superficially - certainly not in accordance with HVCA TR19. They remain a fire risk. And it will be interesting to see who takes the blame if there is a fire resulting in injury or death.
The Fire Safety Order gives powers of prosecution where there has been a failure to take adequate steps to protect a building's occupants. Unless a grease extract system is cleaned according to HVCA TR19 standards, it is likely to remain a fire risk. And those responsible would be well advised to ensure this Standard is being met.
There will be no defence for management to say 'I thought it was being cleaned'. There is a responsibility to make sure any potential hazards are eliminated, and it will not be a mitigation to blame the cleaning contractor.
It is the duty of the responsible person, as prescribed under the legislation, to prepare the fire risk assessment, and make sure proper action is taken to eliminate risks. Unless the grease extract system is being cleaned in accordance with HVCA TR19, it is unlikely to be being fully cleaned.
For those who take their responsibilities seriously, Indepth Hygiene will carry out a detailed survey of the grease extract system free of charge.
The report will describe the fire status of the system and an action plan to eliminate any identified fire risks in accordance with TR19.
For a copy of HVCA TR19 Section 7 or to arrange for a free survey of your grease extract system, call Richard Norman on 010 8661 7888 or email email@example.com