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Kitchen extraction cleaning - fire safety law
The Regulatory Reform (Fire Safety) Order 2005 - the Fire Safety Order - is the main fire safety law for non-domestic premises in England and Wales. It puts duties on a responsible person to assess and manage fire risk. For a commercial kitchen, that includes the grease fire risk in the extraction. Here, in general terms, is what the law demands - and how it connects to keeping the ductwork clean. This is general information, not legal advice.
The short answer
The Regulatory Reform (Fire Safety) Order 2005 - usually called the Fire Safety Order or the FSO - is the main piece of fire safety law for non-domestic premises in England and Wales (Scotland and Northern Ireland have their own equivalent regimes). It is worth understanding in general terms what it demands, because a commercial kitchen's extraction grease risk falls within it. This is general information, not legal advice. Who it applies to - the responsible person: the Order places its duties on a 'responsible person' - in a workplace, typically the employer, and more generally the person who has control of the premises (the owner or occupier). This is the person the law holds responsible for fire safety at the premises. (Who exactly this is, and shared responsibilities in multi-occupied buildings, is covered in who is the responsible person.) What it demands - general fire precautions: the responsible person must take 'general fire precautions' to keep people safe from fire. In broad terms, this means: (1) carry out a fire risk assessment - identify the fire hazards, the people at risk, and evaluate the risk; (2) reduce and manage the risk - put in place appropriate measures to remove or reduce the fire hazards and protect people (and keep those measures maintained); (3) record, plan and review - record the significant findings (required where there are employees or in many cases), have a fire plan, and keep the assessment up to date. So the law demands a considered, acted-upon assessment and management of the fire risk - not a one-off form, but an ongoing duty. How the kitchen extraction fits: in a commercial kitchen, the grease that builds up in the extraction system (filters, canopy, ductwork, fan) is a recognised fire hazard (grease is fuel; a duct fire is a serious risk). So the fire risk assessment should identify this hazard, and the responsible person must manage it - which, in practice, means keeping the extraction clean (removing the grease to control the fuel) at an appropriate frequency, and keeping records (cleaning reports and certificates) to evidence that the risk is being managed. So what the law demands, applied to the kitchen extraction, is that the grease fire risk is assessed and managed - and clean ductwork, with records, is how that is done. So the Fire Safety Order demands the fire risk (including the extraction grease risk) is assessed and managed. This is general information, not legal advice; get a competent fire risk assessment.
Key points
What the Order is
The Regulatory Reform (Fire Safety) Order 2005 - the Fire Safety Order, or FSO - is the main fire safety law for non-domestic premises in England and Wales. It applies to workplaces and other non-domestic premises (offices, shops, restaurants, hotels, factories and the like), setting out the fire safety duties that must be met to keep people safe from fire. It consolidated and replaced a patchwork of earlier fire legislation into one risk-based regime. (Scotland has the Fire (Scotland) Act 2005 and associated regulations, and Northern Ireland its own order - broadly similar risk-based regimes - but the FSO is the England and Wales law.)
The Order's approach is risk-based: rather than prescribing exact rules for every situation, it requires the responsible person to assess the fire risk at their particular premises and take appropriate precautions to manage it. This makes it flexible (fitting all kinds of premises) but also puts the onus on the responsible person to think about their own fire risks and act on them. For a commercial kitchen, that includes thinking about the fire risks specific to a kitchen - among them the grease build-up in the extraction. So the FSO is the overarching, risk-based fire safety law within which a kitchen's extraction fire risk sits. The following sections cover who it applies to, what it demands, and how the extraction fits. So what the Order is: the main fire safety law for premises. This is general information, not legal advice.
Who it applies to
The Fire Safety Order places its duties on a 'responsible person'. In a workplace, this is primarily the employer (so far as the workplace is under their control). More generally, the responsible person is whoever has control of the premises (the owner, the occupier, or the person in control of the business or undertaking carried on there). So for a restaurant or commercial kitchen, the responsible person is typically the business operating it (the employer/occupier) - and possibly, for the building and shared parts, the owner or landlord.
This matters because it identifies who the law holds accountable for the fire safety duties: the responsible person is the one who must ensure the fire risk assessment is done and the fire risk managed. In premises with more than one occupier (a multi-let building, a shared kitchen), there can be more than one responsible person, and they have a duty to cooperate and coordinate - so responsibilities for shared parts (like a shared extraction duct running through a building) need to be clear. (This is explored in who is the responsible person and, for shared extraction, the dark-kitchen split-duties page.) So who it applies to: the responsible person - typically the employer, owner or occupier in control. For the kitchen extraction, it means the responsible person for the kitchen must see that the grease fire risk is managed. So the responsible person is who the Order applies to. This is general information, not legal advice; identifying the responsible person for your premises may need advice.
What it demands
At its core, the Fire Safety Order demands that the responsible person takes 'general fire precautions' to keep people safe from fire - and this breaks down into a few broad duties. Assess: carry out a fire risk assessment - a systematic look at the premises to identify the fire hazards (what could start a fire and what could fuel it), identify the people at risk, and evaluate the risk. Manage: put in place appropriate measures to remove or reduce the fire hazards and protect people - and keep those measures maintained (in working order). This is the acting-on-the-assessment part: actually controlling the risks found. Record, plan and review: record the significant findings of the assessment (required where you have employees, and good practice generally), have arrangements and a plan for fire safety, and review and update the assessment (especially when things change).
So the law demands not a one-off exercise but an ongoing cycle: assess the risk, act to manage it, record it, and keep it under review. The emphasis is on identifying the actual hazards at the specific premises and taking real, maintained measures against them - a considered, acted-upon approach, not a tick-box. For a commercial kitchen, this means the assessment must consider the kitchen's particular fire hazards, and the responsible person must manage them - which brings in the extraction grease risk, covered next. So what it demands: assess, manage, record and review the fire risk. So assess, manage, record and review is what the law demands. This is general information, not legal advice.
How the kitchen extraction fits
For a commercial kitchen, one of the fire hazards that the Fire Safety Order's duties bring in is the grease build-up in the extraction system - so managing it is part of complying. The grease that accumulates in the extraction (on the filters, in the canopy, along the ductwork, on the fan) is a recognised fire hazard: grease is combustible, and a build-up in the ductwork is a serious fire risk (a duct fire can ignite from a flare-up and spread through the system and building). So a proper fire risk assessment of a commercial kitchen should identify this grease build-up as a hazard - and, having identified it, the responsible person's duty to manage the risk applies to it.
Managing the extraction grease risk, in practice, means keeping the extraction clean - removing the grease (the fuel) at an appropriate frequency (matched to the cooking, per the recognised approach, TR19 Grease), so the build-up is controlled and the fire risk kept low. And it means keeping records of the cleaning (reports, before-and-after photographs, certificates) - which evidence that the risk is being managed (useful for the fire risk assessment, for insurers, and if ever questioned). So the extraction grease risk fits into the FSO duties as a hazard to be assessed and managed - and clean ductwork, with records, is how that specific risk is managed. This is the concrete link between the fire safety law and extraction cleaning: cleaning the extraction is part of how a kitchen meets its duty to manage the fire risk. So how the kitchen extraction fits: the grease fire risk to be managed. So the grease fire risk is to be managed. This is general information, not legal advice.
Clean ductwork, risk managed
So what the Fire Safety Order demands, applied to a commercial kitchen's extraction, is that the grease fire risk is assessed (identified in the fire risk assessment) and managed (controlled by appropriate measures, maintained) - and in practice this means keeping the extraction ductwork clean, at an appropriate frequency, with records to evidence it. So clean ductwork is how the extraction fire-safety duty is met in practice - it manages the risk the law requires managing. So clean ductwork, risk managed - how the extraction duty is met in practice.
It is worth being clear about the nature of this: the law does not spell out 'clean your duct every X months' - it demands that the fire risk is assessed and managed, and clean ductwork is the practical, recognised way to manage the specific grease fire risk in a kitchen extraction. The recognised standard for that cleaning is TR19 Grease (setting the cleanliness required and the risk-based frequency), and the records from the cleaning provide the evidence that the risk is being managed. So a kitchen meets this part of its Fire Safety Order duty by having its extraction assessed, cleaned at the appropriate frequency to the standard, and recorded. This is general information, not legal advice - the fire risk assessment should be carried out by a competent person, who will consider the extraction among the kitchen's fire risks, and a competent extraction cleaner keeps the ductwork clean and provides the records. So clean ductwork, risk managed - the extraction fire-safety duty met in practice. This is general information, not legal advice; get a competent fire risk assessment.
Questions
It requires a responsible person for the premises to assess and manage the fire risk - carry out a fire risk assessment, put in place and maintain measures to reduce the risk, and record and review it. The Regulatory Reform (Fire Safety) Order 2005 is the main fire safety law for non-domestic premises in England and Wales. It puts duties on a 'responsible person' (typically the employer, owner or occupier in control) to take general fire precautions: to carry out a fire risk assessment (identifying the fire hazards and people at risk), to reduce and manage the risk with appropriate, maintained measures, and to record the significant findings and keep the assessment under review. It is a risk-based, ongoing duty - assess, manage, record, review - not a one-off form. For a commercial kitchen, this includes managing the grease fire risk in the extraction. So the Order requires the fire risk to be assessed and actively managed by the responsible person. This is general information, not legal advice; get a competent fire risk assessment. So it requires assessing and managing the fire risk.
The grease build-up in the extraction is a recognised fire hazard, so the Order's duty to assess and manage fire risk covers it - and keeping the ductwork clean is how that risk is managed. The Fire Safety Order requires the responsible person to identify and manage the fire hazards at the premises. In a commercial kitchen, the grease that accumulates in the extraction system (filters, canopy, ductwork, fan) is a recognised fire hazard (grease is fuel; a duct fire is a serious risk) - so a proper fire risk assessment should identify it, and the responsible person must manage it. Managing it, in practice, means keeping the extraction clean (removing the grease at an appropriate frequency, per TR19 Grease) and keeping records (reports and certificates) to evidence the risk is controlled. So extraction cleaning is how a kitchen meets its Fire Safety Order duty for the grease fire risk. So the Order applies to extraction cleaning by requiring the grease fire risk to be managed, which cleaning does. This is general information, not legal advice.
The 'responsible person' - typically the employer, or the owner or occupier in control of the premises; in shared buildings there can be more than one, with a duty to cooperate. The Order places its duties on a responsible person: in a workplace, primarily the employer (for the workplace under their control), and more generally whoever has control of the premises (the owner, occupier, or person running the business there). So for a commercial kitchen, it is typically the business operating it, and possibly the building owner or landlord for shared parts. Where premises are shared (a multi-let building, a shared kitchen), there can be more than one responsible person, who must cooperate and coordinate on fire safety - so duties for shared parts (like a shared extraction duct) need to be clear. So the responsible person is who is responsible - usually the employer, owner or occupier. Identifying exactly who it is for your premises may need advice. So the responsible person is responsible. This is general information, not legal advice.
No - it does not set a specific cleaning frequency; it requires the fire risk to be managed, and the recognised way to set the extraction cleaning frequency is the risk-based TR19 Grease approach. The Fire Safety Order is risk-based: it does not prescribe 'clean your duct every X months', but requires the responsible person to assess and manage the fire risk. For the extraction grease risk, managing it means cleaning the ductwork at a frequency appropriate to control the grease - and the recognised standard for setting that frequency is TR19 Grease, which bases it on how much and what kind of cooking you do (heavy or solid-fuel cooking needing more frequent cleaning). So the law demands the risk be managed, and TR19 Grease provides the risk-based method for the cleaning frequency. So the Order doesn't set a frequency, but requires the risk managed - with TR19 Grease giving the risk-based interval. So no fixed frequency - it must be risk-based. This is general information, not legal advice.
Your fire risk assessment (and its review), and records of the extraction cleaning - reports, before-and-after photographs and certificates - which evidence that the grease fire risk is being managed. The Fire Safety Order requires recording the significant findings of the fire risk assessment (where you have employees, and as good practice generally) and keeping it reviewed. For the extraction grease risk specifically, the records that evidence you are managing it are the cleaning records: the reports of each clean, the before-and-after photographs (showing the ductwork cleaned), and the certificates (stating the clean and the standard, TR19 Grease). Keeping these shows that the identified risk is being controlled - useful for your fire risk assessment, for insurers (who often ask for them), and if ever questioned by a fire authority. So keep your fire risk assessment and your extraction cleaning records as evidence of managing the risk. So keep the fire risk assessment and the cleaning records. This is general information, not legal advice.
Failing to comply with the Fire Safety Order can have serious consequences - enforcement action, and in serious cases prosecution - and, separately, an unmanaged grease fire risk can lead to a fire and to insurance problems. The Fire Safety Order is enforced (by the fire and rescue authority), and failing to comply can lead to enforcement notices requiring improvements, prohibition notices restricting use of the premises, and, in serious cases, prosecution with significant penalties. Beyond the legal enforcement, an unmanaged grease fire risk in the extraction is a real danger: a grease-laden duct is more likely to have a fire, which can spread and cause serious damage and harm. And insurers typically require the extraction to be cleaned and evidenced - so a neglected, unmanaged system can jeopardise a fire insurance claim (as covered in the claim-voided pages). So not managing the fire risk carries legal, safety and insurance consequences - reasons to assess and manage it (including keeping the extraction clean). This is general information, not legal advice; take proper advice on compliance. So failing to manage it risks enforcement, fire and insurance problems.
The Fire Safety Order requires the grease fire risk in your kitchen extraction to be managed. Our cleaning removes the grease to TR19 Grease and provides the reports and certificates that evidence the risk is being managed - the practical way the extraction duty is met. Ask us about extraction cleaning and the records you need. This is general information, not legal advice.
