Compliance & responsibility
TR19 is a standard, not a law. But the Fire Safety Order is a law - and it is the reason a greasy duct is your legal problem, not just a hygiene one.
The short answer
The Regulatory Reform (Fire Safety) Order 2005 - the Fire Safety Order - is the main fire safety law for England and Wales. It requires the responsible person for any non-domestic premises to assess and reduce the risk of fire. Grease accumulation in a kitchen extract system is one of the clearest fire hazards a risk assessment can identify, which is precisely why cleaning it is a legal duty. TR19 Grease is not itself law, but it is the recognised standard by which you show the duty has been met.
Who the duty falls on
The Order defines the responsible person as the employer where the workplace is under their control, or otherwise whoever has control of the premises as occupier or owner in connection with a business. That person must make a suitable and sufficient fire risk assessment carried out by a competent person, identify the hazards and who is at risk, and put measures in place to remove or reduce that risk. Where five or more people are employed the assessment must be written, and since the Building Safety Act 2022 the assessment must be recorded in full regardless of headcount.
A fire risk assessment that ignores a grease-laden extract system is not suitable and sufficient. The system runs from the canopy through concealed ductwork to the fan and discharge, and grease throughout it is a fuel path that lets a small cooking fire travel through the building. Addressing that risk means cleaning the whole system on a risk-based schedule and keeping the evidence - which is where TR19 Grease and its certificate come in.
What non-compliance triggers
Fire authorities enforce the Order. Where they find inadequate fire precautions they can issue an alterations notice, an enforcement notice requiring specified works, or - for serious, immediate danger - a prohibition notice that can stop the premises being used. Serious breaches can bring unlimited fines and, in the worst cases, imprisonment. Authorities generally work with the responsible person before formal action, but a visibly neglected extract system with no cleaning records gives them little room.
The financial exposure rarely stops at the fine. An uncleaned system that breaches the Order also tends to breach the lease and invalidate insurance, so a single omission can convert into enforcement, a contractual dispute and a refused claim together. Keeping the system clean and certified closes all three at once.
Discharging the duty
Meeting the Fire Safety Order for your ductwork comes down to one demonstrable act repeated on schedule: a full clean of the extract system to TR19 Grease, verified below 50µm, with a certificate and report your fire risk assessment can reference. That is the evidence a fire officer wants to see - and the thing that turns 'we keep it clean' into a documented, defensible position.
Questions
Not by name. It requires the responsible person to assess and reduce fire risk. A grease-laden extract system is a clear fire hazard, so cleaning it is how you meet that general duty. TR19 Grease is the standard used to show it has been met.
The employer where the workplace is under their control, or otherwise whoever has control of the premises as occupier or owner. In a let kitchen that can include both the tenant and the landlord, each to the extent they have control.
If you employ five or more people it must be written. Since the Building Safety Act 2022 the assessment must be recorded in full regardless of how many people you employ.
Issue an alterations, enforcement or prohibition notice - the last of which can stop the premises being used. Serious breaches can bring unlimited fines and, in extreme cases, imprisonment.
No. TR19 Grease is a BESA specification, not legislation. But it is the recognised benchmark for showing you have met your legal duty under the Fire Safety Order, and it is what insurers and fire officers expect to see.
Phoenix Duct Clean · by the numbers
We clean the extract system to TR19 and hand you the certificate your fire risk assessment needs.