The compliance gap between canopy and duct cleaning

It is the gap between cleaning the visible canopy (which feels like compliance) and cleaning the whole system including the ductwork (which the standard actually requires). A kitchen that has its canopy and filters cleaned sees a clean canopy and has an invoice, so it believes its extraction is cleaned and its fire-safety compliance met. But the recognised standard (TR19 Grease) requires the whole system - canopy, filters and, crucially, the ductwork - cleaned and verified, because the grease build-up throughout, especially in the ductwork, is the fire risk. So a canopy-only clean, leaving the ductwork grease-laden and unverified, does not meet the standard. The compliance gap is this difference: between what was done (the canopy cleaned) and what the standard requires (the whole system cleaned) - between feeling compliant (a clean canopy, an invoice) and being compliant (the whole system cleaned to standard and proven). It is a real exposure that catches out many kitchens, because the visible clean creates a false sense of compliance the hidden uncleaned ductwork belies. So the gap is between the canopy clean done and the whole-system clean required. This is general commentary, not legal advice.

Because the standard requires the whole system, including the ductwork, cleaned - and the ductwork holds the main fire risk that a canopy clean leaves. The standard for kitchen extract cleaning and fire-risk management (TR19 Grease) requires the whole extraction system to be cleaned and verified: the filters, the canopy, and the ductwork throughout (where the grease build-up is the main fire risk), reached through adequate access. A canopy-only clean does only the visible front end (canopy and filters), leaving the ductwork grease-laden and unverified - so it does not meet the standard, and it leaves the main fire risk (the combustible grease in the ductwork) uncontrolled. So cleaning the canopy is not enough for compliance both because the standard requires more (the whole system) and because the point of the cleaning (controlling the fire risk) is not achieved (the ductwork risk remains). A clean canopy is not a clean system. So cleaning the canopy is not enough - the standard requires the whole system, and the ductwork holds the fire risk. This is general commentary, not legal advice.

No - it is a real safety hazard, because the uncleaned ductwork means the main fire risk is uncontrolled. The reason the standard requires the ductwork cleaned is that the grease build-up in the ductwork is the main fire risk in the system (combustible, hard to reach, running through the building, where a grease fire can spread). So a canopy-only clean, leaving the ductwork grease-laden, leaves that main fire risk in place - the compliance gap is, in substance, an uncontrolled fire hazard, not just a failure of a standard on paper. So the kitchen with the compliance gap is not merely failing a standard - it has a real, live fire risk in its ductwork that it believes is handled, exposing it to a serious kitchen fire. The compliance gap and the safety gap are the same gap: the uncleaned ductwork is both non-compliant and a live fire hazard. So no - the compliance gap is not just paperwork; it is a real fire hazard (plus the duty and insurance exposures that follow). So it is a real hazard, not a paperwork issue. This is general commentary.

It means the fire-safety duty is not met (the ductwork fire risk uncontrolled) and creates an insurance exposure (the extraction not cleaned to standard). Fire-safety duty: the responsible person (under the Fire Safety Order) must assess and control the fire risks, including the extraction grease - which means keeping the extraction cleaned to control it. A canopy-only clean does not control the ductwork fire risk (it leaves it), so the duty is not met despite the appearance - which shows if a fire risk assessor or inspector examines the system, and could mean enforcement or a poor assessment. Insurance: insurers commonly expect the extraction cleaned to a recognised standard (TR19 Grease) at appropriate intervals, sometimes as a policy condition - so a canopy-only clean (ductwork uncleaned, standard unmet) may breach a condition or not meet expectations, and if a fire happens, the insurer examining the extraction would find the gap, potentially affecting cover or the claim. So the gap exposes you further: a failure of the fire-safety duty and an insurance exposure, on top of the fire risk itself. So it undermines your duty and your insurance. This is general commentary, not legal or insurance advice.

By ensuring your extraction cleaning does the whole system (including the ductwork) to the standard, and is verified - so you are compliant, not just feeling compliant. To close the gap, insist on a full, whole-system clean: the canopy, filters, and the ductwork throughout, cleaned to the TR19 Grease standard, with adequate access to reach the ductwork - not a canopy-only clean. And insist on verification: internal inspection, before-and-after photographs of the ductwork, and a proper report and certificate, so you can see and prove the whole system (including the ductwork) was cleaned. This turns a canopy-only clean (feeling compliant) into a full, compliant clean (being compliant): the fire risk controlled throughout, the standard met, the duty discharged, and the proof for your fire risk assessment and insurer. So check that the ductwork is included and proven - if a clean does only the canopy, or cannot show the ductwork was done, the gap remains. So close the gap by getting a full, whole-system, verified clean and checking the proof. This is general commentary, not legal advice.

Check whether your extraction cleaning does the ductwork - not just the canopy - and whether you have proof it was cleaned. If your extraction cleaning has been cleaning only the canopy and filters (the visible parts), and you have no evidence the ductwork was cleaned (no internal inspection, no before-and-after photographs of the ductwork, no proper report covering the ductwork), then you likely have the compliance gap - the ductwork uncleaned behind an apparent clean. Signs of the gap: a very cheap 'extraction clean'; a clean that visibly does the canopy but you never see or hear about the ductwork; no access panels (so the ductwork cannot be reached); no photographic or internal-inspection evidence. To be sure, ask your cleaner (or check your records) whether the whole system including the ductwork is cleaned to TR19 Grease, with proof. If not, the gap is there. An audit or survey (inspecting inside the ductwork) can confirm the actual condition. So you know if you have the gap by checking whether the ductwork is cleaned and proven - if it is not, the gap exists. So check for ductwork cleaning and proof to know. This is general commentary.