Duct cleaning and your Fire Safety Order duties

The Fire Safety Order makes the responsible person assess and control the fire risks in the premises, and grease build-up in the extraction ductwork is a real fire risk - so keeping the ductwork clean is how that risk is controlled, making duct cleaning part of meeting the duty. Under the Regulatory Reform (Fire Safety) Order 2005 (England and Wales), the responsible person must make a fire risk assessment (identifying the fire risks) and take general fire precautions (controlling them). Grease build-up in the kitchen extraction ductwork is a combustible, recognised fire risk (a grease fire in the ductwork can spread rapidly) - so it is one of the fire risks the duty covers. Meeting the duty in respect of it means assessing it (the fire risk assessment should cover the extraction grease) and controlling it (keeping the ductwork clean, at an appropriate frequency, to remove the combustible grease), with the records to show it. So duct cleaning is the control measure for the extraction grease fire risk - part of discharging the Fire Safety Order duty, not just good practice. So duct cleaning relates to the Order as the way you control the extraction grease fire risk you are legally required to control. This is general information, not legal advice.

In effect yes - controlling the extraction grease fire risk is a legal duty (under the Fire Safety Order), and keeping the ductwork clean is how that risk is controlled, so it is part of meeting a legal requirement. The Fire Safety Order does not say 'clean your ductwork' in those words, but it requires the responsible person to assess and control the fire risks in the premises - and the extraction grease is a real fire risk, so controlling it is required. The way to control it is to keep the ductwork clean (remove the combustible grease). So keeping the ductwork clean is the means of meeting the legal duty to control that fire risk - making it, in effect, a legal requirement (a failure to keep the ductwork clean is a failure to control a known fire risk, a breach of the duty). Insurers commonly reinforce this by expecting the extraction cleaned to standard too. So while the law frames it as a duty to control the fire risk (rather than a specific instruction to clean), keeping the ductwork clean is how you meet that duty - so it is effectively a legal requirement. So yes - keeping the ductwork clean is part of meeting your legal fire-safety duty. This is general information, not legal advice.

Yes - a suitable and sufficient fire risk assessment for premises with a commercial kitchen should identify and address the extraction grease fire risk. The responsible person's duty is to make a fire risk assessment that identifies the fire risks to people in the premises and what needs to be done about them - and the extraction grease is a significant fire risk in a commercial kitchen (combustible grease that can cause a fast-spreading fire). So a competent fire risk assessment for such premises should consider the extraction and its grease build-up, identify it as a fire risk, and address what is needed to control it (the cleaning, at an appropriate frequency). A fire risk assessment that ignored the kitchen extraction grease would not be suitable and sufficient for premises with a commercial kitchen - it would miss a significant fire risk. So yes - your fire risk assessment should cover the extraction grease fire risk, and specify its control (the cleaning). This is part of meeting the duty to make a suitable and sufficient assessment. So yes - the extraction should be in the fire risk assessment. This is general information, not legal advice; see canopy cleaning and your fire risk assessment.

At an appropriate frequency to keep the fire risk controlled - matched to the cooking (how fast the grease builds up), per the recognised approach (TR19 Grease). The Fire Safety Order requires the fire risk to be controlled, and for the extraction grease that means cleaning the ductwork often enough that the grease does not build up to a hazardous level - so the right frequency depends on how fast the grease accumulates, which depends on the cooking (volume and type). Heavy, greasy or solid-fuel cooking builds up grease fast and needs frequent cleaning; lighter cooking builds up slower and needs less frequent cleaning. The recognised standard (TR19 Grease) and its risk-based approach guide the appropriate frequency for a given kitchen. So there is no single interval for all kitchens - the duty is to clean often enough to keep the fire risk controlled, at a frequency matched to your cooking. A competent extraction cleaner (or your fire risk assessment) can advise the appropriate interval for your kitchen. So the ductwork must be cleaned at a frequency appropriate to keep the fire risk controlled, matched to your cooking. So clean at the frequency that keeps the risk controlled. This is general information, not legal advice.

Yes, in practice - you need to be able to show the fire risk is being controlled, and the cleaning records are how you demonstrate the control measure is carried out. The Fire Safety Order requires the fire risk assessment and control measures to be in place, and a responsible person needs to be able to demonstrate that the identified risks are being controlled - to a fire inspector (who can inspect and ask for evidence) and as part of sound fire-safety management. For the extraction grease risk, that means keeping the records of the cleaning (the certificates and reports showing the ductwork was cleaned to standard at the right intervals) - evidence that the control measure (the cleaning) is being carried out. Without the records, you cannot demonstrate the risk is controlled (even if the cleaning is done), which weakens your fire-safety position and could be a problem at inspection or after a fire (and for insurance). Linking the cleaning records to the fire risk assessment shows the assessed risk is being controlled. So yes - you need the duct cleaning records, to show the fire risk is being controlled as your duty requires. So keep the records to demonstrate the control. This is general information, not legal advice.

Not controlling a known fire risk is a failure of your Fire Safety Order duty - with potential enforcement, and serious consequences if a fire happens. The responsible person is legally required to assess and control the fire risks in the premises. The extraction grease is a known, significant fire risk - so failing to control it (not keeping the ductwork clean, letting the grease build up) is a failure to control a known fire risk, a breach of the duty. The consequences can be serious: enforcement by the fire authority (who can inspect, issue notices, and prosecute for breaches - fire-safety breaches can carry significant penalties); a heightened, uncontrolled fire risk (making a serious fire more likely); and, if a fire happens, the consequences of that fire (damage, injury, potential liability) plus the exposure of having failed the duty (and likely insurance problems, as insurers expect the extraction cleaned). So not controlling the extraction fire risk exposes you legally (breach of duty, enforcement), physically (a real fire risk), and financially (a fire, and insurance exposure). This is why controlling it - keeping the ductwork clean, with records - matters. So not controlling it is a breach of duty with serious potential consequences. This is general information, not legal advice.