Compliance & responsibility
The canopy is the part everyone can see - and cleaning only what you can see is the single most common way a kitchen believes it is compliant when it is not.
The short answer
TR19 Grease compliance covers the entire extract system - from the canopy and filters through the horizontal and vertical ductwork to the fan and the discharge point. A great many kitchens clean the canopy and filters, which are visible and easy to reach, and stop there. That leaves the concealed ductwork behind the canopy untouched - and a canopy-only or filter-only clean is not TR19 compliant. The gap between what was cleaned and what should have been is where the fire risk, the failed audit and the refused claim all live.
Where the grease actually is
Grease does not stop at the canopy. Airborne fat, oil and grease is carried up into the ductwork on the extract stream and deposits along its whole length - in the horizontal runs above the ceiling, up the vertical risers, on the fan blades and toward the discharge. Those concealed sections are harder to reach, which is exactly why they get skipped, and exactly why the grease there is more dangerous: it is thicker, older and closer to ignition sources like the fan.
A spotless canopy over a grease-laden duct is worse than useless as reassurance, because it looks compliant. In a fire, that concealed grease is the fuel path that carries flame from the cookline through the building. In an audit or an insurance review, the moment someone opens an access panel and looks inside the duct, the canopy's shine counts for nothing. The system is judged on the whole run, not the visible end of it.
Closing the gap
Closing the compliance gap needs two things. First, access - the concealed ductwork can only be cleaned and inspected if there are enough access panels along it, positioned to reach every section. Where panels are missing, they have to be retrofitted before a genuine clean is even possible; without them the system simply cannot be cleaned to bare metal. Second, a clean that follows the whole system from canopy to discharge and verifies each section below 50µm, not just the parts on show.
The certificate is where the gap is finally exposed or closed, because it records whether the clean was full or partial. A partial-clean certificate is honest about what was left - and tells an insurer or fire officer exactly where to look. A full-clean certificate, backed by readings and matched before-and-after photographs from inside the ductwork, is the only document that says the whole system, not just the canopy, is compliant.
No gap left to find
The way to be sure there is no compliance gap is to clean the whole system in one go and certify it as such. A full canopy-to-discharge clean to TR19 Grease - fitting access panels first where they are missing, verifying every section below 50µm and issuing a full-clean certificate - leaves nothing concealed and nothing for an inspector or insurer to uncover later.
Questions
No. TR19 Grease covers the whole system from canopy through the concealed ductwork to the fan and discharge. A canopy-only or filter-only clean is not compliant, however clean the canopy looks.
Grease is carried up into the ducts and deposits along their whole length, including the risers and fan. Those hidden sections carry thicker, older grease near ignition sources, and they are the fuel path a fire travels along.
Check whether the concealed ductwork can actually be reached and cleaned, and read your last certificate. If it says partial, or the ducts have no access panels, there is almost certainly a gap.
Openings in the ductwork that let the concealed sections be cleaned and inspected. Without enough panels, properly positioned, the system cannot be cleaned to bare metal - so missing panels are usually where the gap begins.
By fitting access panels where they are missing, cleaning the whole system from canopy to discharge, verifying every section below 50µm, and issuing a full-clean certificate that leaves nothing concealed.
Phoenix Duct Clean · by the numbers
We clean the whole system - canopy to discharge - and certify it, so there is no gap left to find.