In Compliance With NFPA 96

A RECENT NFPA 101®, LIFE SAFETY CODE®, committee meeting for healthcare occupies included a discussion about when cooking operations should be required to be protected.

The conversation was triggered by a proposal for the 2015 edition of the code that would allow portable cooking devices in certain areas in nursing homes.

In a larger sense, the discussion was a continuation of the many changes made to the 2012 Life Safety Code that allow health care occupies, particularly nursing homes, to become more residential, or homelike, for residents.

The changes included allowing limited items in corridors, allowing residential or commercial cooking for 30 or fewer persons to be open to the corridor, and other major amendments.

The new proposed changes include allowing devices such as microwave ovens, hot plates, and electric skillets for reheating and limited cooking.

Subsection 9.2.3 of the Life Safety Code covers commercial cooking equipment and references NFPA 96, Ventilation Control and Fire Protection of Commercial Cooking Equipment. It is important to note that both documents use the term “commercial cooking equipment.

The scope of NFPA 96 states that it applies to both public and private cooking operations, including residential cooking equipment used for commercial purposes, though it does not apply to cooking equipment located in a single dwelling unit. The scope also excludes cooking where only residential equipment is used, a fire extinguisher is located in the kitchen, the facility is not an assembly occupancy, and the authority having jurisdiction has approved the installation.

An annex note to the scope further states that the judgment should include consideration of the items being cooked, the type of cooking — for example, deep fat frying versus oven baking — and frequency of cooking.

The annex also states that this standard applies to “… all other auxiliary or ancillary components or systems that are involved in the capture, containment, and control of grease-laden cooking effluent” and includes examples of operations that may not require compliance with NFPA 96, such as daycare centers that warm bottles and lunches, therapy cooking in health care occupies, and others.

The Life Safety Code also allows limited cooking in certain occupies. Typically, the limitations are that the equipment be a residential type and that it only be used for food warming or limited cooking. Such provisions are found in Chapters 15 and 16 for new and existing day care facilities, and Chapters 20 and 21 for new and existing ambulatory health care.

For other occupies, the code includes provisions permitting cooking operations that are not protected in accordance with NFPA 96 where it is outdoor equipment, portable equipment that is not flue-connected, or equipment that is used only to warm food.

The bottom line is that not all cooking operations require protection in accordance with NFPA 96, which does not address cooking equipment but rather the quantity of grease-laden vapors produced and whether that quantity is sufficient to warrant protection.

If the requirements of NFPA 96 do apply to cooking operations producing grease-laden effluent, then the Type I (liquid tight) hood and exhaust duct and the fixed extinguishing system are required. However, there are many cases where only food warming or limited cooking are done, and NFPA 96 requirements are not applicable.


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Fire department has given ample warnings of kitchen exhaust-hood risks

The Post and Courier ran a front-page story titled “Hidden Danger,” reporting on the dangers associated with commercial kitchen exhaust hoods that are not cleaned on a regular maintenance schedule by restaurant owners.

I am responding to this story because it missed a number of critical facts and contained information that was not correct.

The most important fact that was ignored is that the fire department has been very active in working with the restaurant community and providing them with information on the requirements of the International Fire Code and the critical need to keep their kitchen hood systems clean to avoid fires.

The International Fire Code (IFC) requires owners, landlords and tenants who run commercial kitchens to routinely clean, service and keep up the exhaust systems of their cooking operations.

This ensures that the exhaust hood operates properly so that their fire suppression systems have the ability to act as designed.

The code also requires that records of cleaning and inspection activities must be kept on site at commercial establishments and available to the fire code official upon request.

Since 2011, the City of Charleston Fire Department has met with about 1,000 restaurant owners and employees about the need for regular kitchen hood cleaning.

These contacts have included training restaurant staff members about prevention and safety, the need to be concerned about grease accumulation, and the dangers inherent in hoods coated with grease Information has been widely distributed to restaurants on King Street, other restaurants in historic buildings on the peninsula, and throughout the city about current code requirements.

We have reached out to local professional organizations for their help in distributing this information to their members.

Our primary focus has been to educate the business owners, landlords and tenants about the requirements and offer the assistance of our fire safety inspectors.

Most importantly, since 2011, when the fire marshal’s office undertook an aggressive approach with restaurants to seek their compliance with the code regulations surrounding the routine cleaning and inspection of kitchen vent systems, we can name only one incident that may have been related to an ignition within the exhaust system of an unclean hood.

The fire at Anson’s Restaurant is still under investigation but at this point, there is no evidence that the fire was caused by grease accumulation on the exhaust hood of the kitchen equipment.

We believe that it is essential to give the public correct and complete information about the proactive steps that have already been implemented by the Charleston Fire Department and our ongoing efforts.

We will continue to work on this important public safety issue through partnerships with restaurants, hood cleaning businesses, and hospitality groups since we all have an interest in the protection of the citizens of and visitors to this remarkable city.

We will continue the aggressive outreach efforts by our fire safety inspectors to have direct contact with owners, landlords and tenants as well as developing a more formal reporting program.

Going forward, we will be working with the city attorney’s office to find if we have the authority to impose additional reporting and other requirements related to commercial kitchen cleaning/inspection programs.