TR19 and the law ·
TR19 regulations: is TR19 a legal requirement?
No. TR19 is a specification published by BESA, the Building Engineering Services Association, not legislation. What the law does require is that fire risk is managed: under the Regulatory Reform (Fire Safety) Order 2005 the responsible person must assess the fire risk and take precautions, and grease inside a kitchen extract system is a fire risk the assessment should cover. Cleaning to TR19 is the recognised way to show that grease has been dealt with, and your insurance policy may make it a condition of cover, which is a contract term rather than law.
This page explains the position in general terms. It is not legal advice about your premises.
The law that does apply to kitchen extraction
No law names TR19. Four pieces of law cover what a commercial kitchen extract system has to do, and each of them is met in practice by keeping the system clean and being able to show it.
Regulatory Reform (Fire Safety) Order 2005
Non-domestic premises in England and Wales · Enforced by Local fire and rescue authority
- What it requires
- The responsible person (usually the operator or employer) must carry out a suitable and sufficient fire risk assessment (article 9) and take general fire precautions (article 8).
- Where the extraction system fits
- Grease in the canopy, ductwork and fan is fuel in a channel that runs through the building. The assessment should identify it and say how it is controlled: in practice, how often the system is cleaned and how you know it was done.
Health and Safety at Work etc. Act 1974
Every workplace · Enforced by Local authority environmental health (most catering) or HSE
- What it requires
- Employers, and anyone in control of premises used as a workplace, must take reasonable measures, so far as reasonably practicable, to keep premises, plant and equipment safe and without risks to health.
- Where the extraction system fits
- The extraction system is plant. Leaving it to fill with grease is a foreseeable risk to staff and others.
Workplace (Health, Safety and Welfare) Regulations 1992
Every workplace · Enforced by Local authority environmental health or HSE
- What it requires
- Regulation 6 requires effective and suitable ventilation in every enclosed workplace; regulation 5 requires workplace equipment and systems to be maintained in efficient working order and good repair.
- Where the extraction system fits
- The kitchen canopy and extract are how a catering kitchen meets regulation 6, so they have to be kept working.
Food hygiene rules: Regulation (EC) 852/2004, Annex II (retained in UK law)
Food businesses · Enforced by Local authority environmental health (food hygiene inspections)
- What it requires
- Food premises are to be kept clean and maintained in good repair, and ventilation systems are to be constructed so that filters and other parts needing cleaning are readily accessible.
- Where the extraction system fits
- Grease filters and ductwork have to be reachable for cleaning, which is why access panels matter.
Where TR19 fits
The law says the grease risk must be managed; it does not say how. BESA's TR19 Grease specification is the UK's recognised method for cleaning grease extract systems: what has to be cleaned (canopy, filters, plenum, ductwork, fan and discharge), how often, how grease is measured before and after, and what the paperwork should record.
That is why a fire risk assessment, a landlord or an insurance policy may name it. Following TR19 is the straightforward way to show the risk has been dealt with; doing something else leaves you to prove your own method was as good.
What the clean leaves behind is the evidence: a certificate and a post-clean report. What a TR19 certificate must contain.
Insurance: a contract term, not law
A commercial kitchen policy may carry a condition or endorsement about extract cleaning. Where yours does, it is part of your contract with the insurer, and it can be stricter than the law: it may name TR19, set a cleaning interval, and ask for the certificate as evidence.
Read the policy schedule and any endorsements, and match your cleaning interval to whichever is shorter: the policy's or TR19's. Kitchen extract cleaning and your insurance.
What the HSE says
HSE's catering guidance on kitchen ventilation does not mention TR19 by name. On cleaning and maintenance it says:
“There should be suitable access to the ductwork to allow regular cleaning to prevent accumulation of fat etc.”
“Mechanical ventilation systems should be maintained in efficient working order in accordance with the manufacturer's/installer's instructions.”
Source: Ventilation in catering kitchens, HSE Catering Information Sheet No 10, CAIS10 (rev3), July 2017.
What to keep on file
If a fire officer, an environmental health officer, your landlord or your insurer asks how the extraction system is managed, this is what answers them:
- A current fire risk assessment that mentions the kitchen extraction system
- The TR19 certificate from the last clean, naming which parts of the system were cleaned
- The post-clean report: grease readings before and after, and dated photographs
- The date the next clean is due, set by your cooking hours and any insurance condition
- A note of any section that could not be reached, and what is being done about it
Check what you already hold with the TR19 checklist or the certificate checker.
TR19 and the law: common questions
Is TR19 a legal requirement?
No. TR19 is a specification published by BESA, the Building Engineering Services Association, not legislation. What the law does require is that fire risk is managed: under the Regulatory Reform (Fire Safety) Order 2005 the responsible person must assess the fire risk and take precautions, and grease inside a kitchen extract system is a fire risk the assessment should cover. Cleaning to TR19 is the recognised way to show that grease has been dealt with, and your insurance policy may make it a condition of cover, which is a contract term rather than law.
Is TR19 mandatory?
Not by law. It becomes binding in two ways: when your insurance policy makes cleaning to TR19 a condition of cover, and when your fire risk assessment relies on it as the way the grease risk is controlled. In both cases you then need to be able to show it was done.
What does the HSE say about TR19?
HSE's catering guidance on kitchen ventilation (Catering Information Sheet 10) does not mention TR19 by name. It says there should be suitable access to the ductwork to allow regular cleaning to prevent accumulation of fat, and that mechanical ventilation should be maintained in efficient working order. It points designers to BESA and CIBSE for technical guidance.
How often does the law say kitchen extraction must be cleaned?
The law sets no interval. BESA TR19 Grease sets one by how many hours a day the kitchen cooks: every 3 months for 12 to 16 hours, every 6 months for 6 to 12 hours, every 12 months for 2 to 6 hours. Your insurance policy may set its own interval, and where it does, that is the one to follow.
Who enforces kitchen extraction fire safety?
The local fire and rescue authority enforces the Regulatory Reform (Fire Safety) Order 2005. Environmental health officers from the council inspect food hygiene and, in most catering premises, health and safety. Your insurer is not an enforcer, but its policy conditions are part of your contract.
What happens if my kitchen extraction has not been cleaned?
Nothing automatic, but you carry the risk. Grease keeps building up where it cannot be seen. A fire risk assessment that ignores it, or precautions that are not carried out, can lead to enforcement action by the fire and rescue authority, and a missed insurance condition is a breach of your policy terms. The practical fix is a clean, a certificate, and a date for the next one.
Does this apply in Scotland and Northern Ireland?
The Regulatory Reform (Fire Safety) Order 2005 covers England and Wales. Scotland has the Fire (Scotland) Act 2005 and Northern Ireland the Fire and Rescue Services (Northern Ireland) Order 2006, which place similar duties to assess and manage fire risk. TR19 is guidance in all four nations.
Where can I get the TR19 document?
TR19 Grease is published and sold by BESA, which holds the copyright, so it is not free to download. Our free TR19 checklist sets out what a compliant clean should cover and what the paperwork should show, without reproducing the standard.