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Extraction cleaning - the law

Are you legally required to clean your kitchen ductwork?

There is no law that says the words clean your ductwork - but there is a legal duty to manage the fire risk that greasy ductwork creates. Between the Fire Safety Order and your insurer, cleaning it is not really optional.

RRFSO 2005
The legal duty
Fire risk
What you must manage
Insurance
What makes it firm
Established 2001UK-wideFully insuredCertificated and photographed

The short answer

Yes, in effect - through fire-safety law and your insurance

No single regulation orders you to clean kitchen ductwork by name. What the law does require, under the Regulatory Reform (Fire Safety) Order 2005, is that the responsible person assesses and manages fire risk - and grease-laden extract ductwork is one of the clearest fire risks in a catering building. Cleaning it to a recognised standard is how you meet that duty, and your insurer will usually require it in writing on top.

The legal duty

The Fire Safety Order makes the risk your responsibility

The Regulatory Reform (Fire Safety) Order 2005 places a duty on the responsible person for a premises - typically the employer, owner or occupier - to carry out a fire risk assessment and take steps to reduce the risks it identifies. It does not list tasks like duct cleaning; it makes you responsible for the outcome, which is a building where fire risk is properly managed.

In a catering premises, a grease-coated extract system is a textbook risk for that assessment to catch. Grease is combustible, it accumulates out of sight in the ductwork and risers, and a cookline flare-up can travel it through concealed voids between floors. Managing that risk means keeping the system clean - which is why, although the Order never says so directly, duct cleaning is how catering businesses discharge the duty in practice.

The standard behind it

TR19 Grease is how you show it was done

A fire risk assessment that flags greasy ductwork needs evidence that the risk is being controlled. TR19 Grease, the BESA standard for grease in kitchen extract systems, is the recognised way to provide it: the system is cleaned and measured to a defined level, and you get a dated certificate, grease-depth readings and photographs.

So the two fit together. The Fire Safety Order creates the duty; TR19 Grease is the accepted method and evidence for meeting it. A fire officer, a fire risk assessor and an insurer will all recognise a current TR19 Grease certificate as proof the extract-fire risk is being managed.

Assess
Identify the grease-fire risk
Control
Clean the system to standard
Evidence
Certificate, readings, photographs

Where it becomes non-negotiable

Your insurance policy usually settles it

Even where an operator might argue about the fine print of the Fire Safety Order, insurance tends to remove the choice. Most commercial policies covering premises with a kitchen require extract cleaning to a stated frequency, certificated, as a condition of cover. It is often in the policy conditions rather than the headline.

The consequence is blunt: if a fire starts and the system was not cleaned and certified as required, the insurer can reduce or refuse the claim on the grounds a condition was not met. For most operators that risk, more than the prospect of an inspection, is what makes cleaning the ductwork genuinely unavoidable.

What this means for you

If you run a commercial kitchen, treat it as required

Put the pieces together and the practical position is clear. If you operate a commercial kitchen with powered extraction, the law requires you to manage the fire risk, the recognised way to do that is TR19 Grease cleaning, and your insurer almost certainly requires it in writing. Whether or not a single statute uses the words, the safe and correct assumption is that you are required to keep your ductwork clean and certified.

The sensible step is a survey: it tells you the current state of the system, sets a cleaning frequency for how you cook, and puts you on a documented cycle so the duty is met and the evidence is always to hand.

Who the duty falls on

The responsible person, not the cleaner

It is worth being clear who carries this duty, because it does not transfer with the mop. The Fire Safety Order places it on the responsible person for the premises - usually the employer, owner or occupier, and in shared buildings sometimes more than one party. Hiring a cleaning company carries out the task, but the legal responsibility for making sure the risk is managed stays with you.

That matters in practice. It means keeping the certificates, acting on what a survey finds, and making sure the frequency actually happens rather than assuming someone else is tracking it. If a fire officer or an insurer asks who is responsible for the extract-fire risk, the answer is the responsible person - which is why the paperwork needs to live with you, not just with your contractor.

Frequency is part of the duty

Cleaning once is not managing a risk

Managing a fire risk is an ongoing duty, not a single action. Grease rebuilds as soon as cooking resumes, so a system cleaned once and left drifts straight back into risk. Meeting the duty properly means cleaning at a frequency matched to how the kitchen is used, and keeping that up - which is why the standard sets intervals by cooking hours rather than treating a clean as a permanent fix.

This is also what an assessor looks for: not a one-off certificate from two years ago, but a current one and a pattern of cleaning at sensible intervals. A documented cycle shows the risk is being managed continuously, which is the whole substance of the duty.

The practical test

If in doubt, assume it applies

There is a simple way to cut through the legal nuance. If your premises has a commercial kitchen with powered extraction over hot cooking, the safe assumption is that you must keep the ductwork clean and certified - because the fire-safety duty applies, the recognised method is TR19 Grease, and your insurer very likely requires it in writing. Looking for an exemption is rarely worth the risk of being wrong.

The constructive step is not to debate whether you are caught, but to get a survey that tells you the state of the system and sets a frequency. That satisfies the duty, gives you the evidence, and removes the uncertainty in one move - which is far cheaper than defending a gap after a fire or an inspection.

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Questions

Frequently asked questions

Is cleaning kitchen ductwork a legal requirement?

In effect, yes. No regulation names the task, but the Regulatory Reform (Fire Safety) Order 2005 requires you to manage fire risk, and greasy extract ductwork is a clear fire risk. Cleaning it to a recognised standard is how you meet that duty.

Which law applies?

The Regulatory Reform (Fire Safety) Order 2005, which makes the responsible person assess and control fire risk in the premises. It sets the duty rather than the specific task.

How do I prove I have managed the risk?

With a current TR19 Grease certificate, grease-depth readings and photographs, which a fire officer, fire risk assessor and insurer all recognise as evidence the extract-fire risk is controlled.

Does my insurance require it?

Almost certainly. Most commercial policies covering a kitchen require extract cleaning to a stated frequency, certificated, as a condition of cover - often in the policy conditions rather than the headline.

What happens to a claim if we have not cleaned it?

If a fire occurs and the system was not cleaned and certified as required, the insurer can reduce or refuse the claim on the grounds a policy condition was not met.

How often do we need to do it?

It depends on cooking volume. A survey and grease-depth readings set the right frequency, which is then recorded so the duty is continuously met.

Make sure your ductwork duty is covered

We will survey your extract system, clean it to TR19 Grease and give you the evidence your insurer and fire risk assessor expect.