TR19 & standards
Shared risers, split leases and more than one Responsible Person - how TR19 Grease duty really works when several kitchens share one building.
The short answer
In a multi-occupied building, TR19 Grease compliance rarely sits with one party. Under the Fire Safety Order there is usually more than one Responsible Person, each accountable for the area they control. The lease decides who arranges and pays for cleaning the shared extract - but it does not remove anyone's legal duty, and a gap on the shared riser can undermine the whole building's insurance.
Who controls what
Fire safety in a shared building is easiest to understand in layers. The freeholder or landlord typically controls the structure, the common parts, plant rooms and the shared service risers. Each tenant controls their own demise - the unit they lease. The Regulatory Reform (Fire Safety) Order 2005 attaches responsibility to whoever has control of each layer, which is why a multi-tenant building normally has several Responsible Persons at once, each accountable for their patch regardless of what the others do.
Kitchen extract is the layer that causes trouble, because it crosses boundaries. A canopy sits inside a tenant's demise, but the duct often runs up a shared riser or through common parts to a roof fan the landlord controls. So a single grease-laden system can involve a tenant, a managing agent and a freeholder - and everyone can assume someone else has it covered.
Lease versus statutory duty
Leases routinely allocate who arranges and pays for extract cleaning, and a well-drafted one will name the shared duct explicitly. But allocation in a lease is a contract between the parties - it does not switch off the statutory duty each Responsible Person carries under the Fire Safety Order. You can delegate the job of cleaning; you cannot delegate away the legal responsibility for fire safety in the area you control.
The Order also builds in co-operation. It requires a Responsible Person to maintain fire safety facilities and lets them make arrangements with the occupier of other premises in the building, and it obliges those occupiers to co-operate and co-ordinate. In practice that means landlord and tenants are legally expected to work together on the shared extract - not to leave it in a gap between their leases. Multi-occupancy also calls for a fire risk assessment for each part plus one that coordinates the whole building.
Protecting the whole building
Insurance exposure runs both ways. A tenant's un-evidenced clean can undermine the landlord's buildings cover; a landlord's neglected shared riser can undermine a tenant's claim. After a fire, everyone is asked the same question - was the system cleaned to TR19 Grease, and can you prove it? One weak link leaves the whole building's cover open to challenge.
The practical answer for landlords and operators is trust but verify. Require TR19 Grease compliance and audit rights in the lease, collect each tenant's post-clean certificate, and commission an independent audit of the shared system. A certificate on its own is not proof the work was done properly - the audit checks the ductwork behind it, so the paperwork and the reality match.
Questions
Usually more than one party. Under the Fire Safety Order each Responsible Person is accountable for the area they control. The lease decides who arranges and pays for the shared duct, but every Responsible Person keeps a legal duty for fire safety in their part.
The lease allocates who arranges and pays for cleaning, and a good one names the shared duct. But it cannot remove the statutory fire-safety duty - you can delegate the task, not the legal responsibility.
Yes. Cover runs both ways in a shared building. An un-evidenced clean by a tenant can undermine the landlord's buildings policy, and a neglected shared riser can undermine a tenant's claim, so one gap can put the whole building's cover at risk.
Trust but verify: require TR19 Grease compliance and audit rights in the lease, collect each tenant's post-clean certificate, and commission an independent audit of the shared system rather than relying on paperwork alone.
Yes. The Fire Safety Order requires jointly responsible persons to co-operate and co-ordinate, and lets a Responsible Person make arrangements with other occupiers - so the shared duct should not fall into a gap between leases.
Phoenix Duct Clean · by the numbers
Landlord or tenant, we clean, certify and audit shared kitchen ductwork so the whole building can prove compliance.