It’s one of the most common questions we hear from kitchen owners: is TR19 a legal requirement? The short answer is no. TR19® Grease is a specification written by BESA, the Building Engineering Services Association. It isn’t an Act of Parliament or a regulation. But that doesn’t mean cleaning is optional. The law requires you to manage fire risk, and in a commercial kitchen that means keeping grease in the extract system under control. TR19 is the benchmark most people use to show they’ve done it.
This guide explains what the law actually says, where TR19 fits, and why insurers and inspectors ask for it.
What TR19 is, and what it isn’t
TR19® Grease is BESA’s standalone specification for managing the fire risk from grease in kitchen extract systems. It sets out how systems should be inspected, how grease is measured, how often cleaning is needed as a minimum and what records should be kept. BESA itself says plainly that “TR19® itself is not legislation” (BESA, Ventilation Hygiene Standards).
So nobody will prosecute you simply for not following TR19. What matters is whether you met your legal duties, and following TR19 is the accepted way of showing that you did.
The law: the Fire Safety Order 2005
In England and Wales, the law that applies is the Regulatory Reform (Fire Safety) Order 2005. It puts duties on the “responsible person” for the premises. That person must carry out a fire risk assessment, take steps to reduce the risks it finds, and keep fire safety measures maintained.
Grease in a kitchen extract is fuel. A flare-up on the range can be drawn into the canopy and duct, and a fire in the ductwork can spread through the building. A fire risk assessment for a commercial kitchen should therefore deal with the extract. In practice, that means regular cleaning and inspection to a recognised standard. GOV.UK has a plain-English summary of these workplace fire safety responsibilities, and our guide to the responsible person goes into more detail.
Need it done? Duct Doctor cleans and tests kitchen extract and ventilation systems across London and the South East, with a certificate and photo report after every clean. Get a fixed quote.
Why insurers ask for TR19
Insurance is where TR19 most often becomes a hard requirement. BESA notes that many insurers require proof of regular cleaning and inspection, and many policies explicitly require adherence to TR19 (BESA, Kitchen Extract System Cleaning). If there’s a fire and you can’t show the extract was cleaned to the standard your policy asks for, the insurer can refuse or reduce a claim.
Read your policy wording. If it mentions TR19 or “a competent contractor”, that’s a condition you need to meet, whatever the law says. Our guide to what insurers want lists the evidence worth keeping.
Food safety and EHOs
Food businesses also come under the Food Safety Act 1990 and food hygiene rules, enforced by environmental health officers (EHOs) from the local council. EHOs look at the cleanliness of the premises and equipment, and that includes the canopy, filters and extraction. A greasy, dripping canopy can count against you at an inspection. See EHOs and kitchen extraction for what they tend to look at.
What this means in practice
Treat TR19 as the standard you work to, even though it isn’t law. That gives you a clear answer for each of the people who might ask:
- A fire officer can see that the fire risk from grease is being managed.
- Your insurer can see certificates that meet the policy wording.
- An EHO can see a clean, maintained system.
Keep every certificate and report in your maintenance log. Duct Doctor issues a TR19® certificate and a photo report after every kitchen extract clean, so you have the evidence in one place.
Quick answers
Is TR19 the law?
No. It’s BESA’s specification. The law is the Regulatory Reform (Fire Safety) Order 2005, which requires the responsible person to manage fire risk.
Can I be fined for a dirty extract?
Enforcement under fire safety law is about failing to manage fire risk. A heavily greased extract can be evidence of that, whatever standard you claim to follow.
Does my insurer need TR19?
Many policies require it. Check your wording, and keep every certificate and report.
Who decides how often we clean?
TR19 sets minimum intervals by hours of use. Grease readings taken by a competent person show whether your kitchen needs cleaning more often.
Related services
More advice
- TR19 Explained: Kitchen Extract Cleaning Standard
- The Responsible Person Under the Fire Safety Order
- Kitchen Extract Insurance: What Insurers Want to See
- What EHOs Look For in Kitchen Extraction
- All advice
This guide is general information. It isn’t legal or insurance advice: check your own policy wording and lease, and speak to a qualified adviser about your fire risk assessment.