Phoenix Journal · Extraction
The Regulatory Reform (Fire Safety) Order 2005 puts the safety of your building on one named person - and grease-laden extract ductwork is squarely within its reach. Here is what the law actually asks of you, and the two very different ways people choose to meet it.
Fire safety law
The Regulatory Reform (Fire Safety) Order 2005 is the single piece of legislation that governs fire safety in almost every commercial building in England and Wales, and it lands on one set of shoulders - the responsible person.
The Order came into force on 1 October 2006, sweeping away more than seventy older laws and the old fire certificate system. In its place it names a responsible person - under Article 3, usually the employer, occupier or whoever controls the premises for the running of a trade or business - and hands them a clear, continuing duty to keep everyone safe. That duty is not a one-off form. It requires a suitable and sufficient fire risk assessment, kept up to date, and it requires you to actually carry out the general fire precautions that assessment identifies.
For a commercial kitchen, one of those precautions is rarely optional. Grease vapour drawn off the cooking line settles inside the canopy, the filters and the full run of extract ductwork, where it becomes a concentrated layer of fuel sitting directly above an ignition source. A fire that starts on the range can travel that greasy duct through walls and floors in minutes. Article 17 of the Order requires that fire safety equipment - and that includes your ventilation and extract system - is kept in efficient working order and good repair. In plain terms, the law expects the grease gone. The Fire Safety Act 2021 and the Fire Safety (England) Regulations 2022, in force from 23 January 2023, tightened the wider regime further, and the teeth are real - since 1 October 2023 the maximum fine moved from £1,000 to unlimited, with up to two years’ imprisonment for the most serious breaches.
So the question is not really whether the Order applies to your extract system - it does. The question is how you choose to satisfy it. Broadly, responsible persons take one of two routes, and the difference between them is the difference between hoping and proving.
The Order is written in general, risk-based language. It tells you the outcome it wants - a safe building, a maintained system - but it does not print a cleaning schedule or a cleanliness figure. That leaves room for a responsible person to argue they have done “enough” by cleaning when the system looks dirty, using a general contractor, and keeping a simple invoice as a record.
The second route is to clean to the benchmark the industry, insurers and enforcing authorities all recognise - BESA’s TR19 Grease, the standalone specification published in 2019 for fire risk management of grease in kitchen extract systems. It is not itself a law, but it is the accepted way of showing you have met your duty under the Order. It sets a measurable target - post-clean grease deposits below 50 microns - carried out by technicians holding the BESA Grease Hygiene Technician qualification, with a report and photographic evidence logged afterwards.
Strip away the debate and three numbers frame the choice. They explain why so many responsible persons move from the first route to the second once they see what is at stake.
The Order does not care which method you name - it cares whether you can show the building is safe and the system maintained. The first route leaves that showing to chance; the second puts a measured, dated, independent record in your hands. Given that the downside is now unlimited and personal, most responsible persons decide that proof is the cheaper option.
Questions
Under Article 3 of the Regulatory Reform (Fire Safety) Order 2005, the responsible person is usually the employer, occupier or whoever controls the premises for the running of a business - so in most commercial kitchens it is the operator or business owner. That duty includes keeping the ventilation and extract system in efficient working order under Article 17. You can appoint a competent contractor to carry out the cleaning, but the legal responsibility for the outcome stays with you.
No, TR19 Grease is a specification published by BESA, not a law in itself. However, it is the recognised way of demonstrating that you have met your legal duty to maintain the extract system under the Fire Safety Order, and most insurers expect cleaning to that standard. Without evidence of a TR19 Grease clean, an insurer can treat a fire claim as invalid, so in practice it functions as the benchmark you are measured against.
Since 1 October 2023 the maximum fine for a serious breach of the Fire Safety Order is unlimited, having previously been capped at £1,000. The most serious breaches can also carry up to two years' imprisonment for the individuals responsible. Fines have risen sharply since the Sentencing Council guideline of 2016 and the Grenfell inquiry, so an unproven or neglected extract system is a genuine business risk, not a paperwork technicality.
Phoenix Duct Clean · by the numbers
The right kit only helps if the system stays clean. Phoenix degreases canopies, filters and ductwork to TR19 Grease - UK-wide, overnight.