By David Glover, Technical Director, Plasma Clean Air Limited
If you’re a building landlord or facilities operator responsible for a shopping centre with food tenants, it’s essential to understand your obligations around fire safety. One area that is often overlooked—or simply taken on trust—is the quality of kitchen extract cleaning carried out by tenants or contracted service providers.
Yet this is where the risk lies.
A grease-laden extract system is one of the leading causes of commercial kitchen fires. And if that system hasn’t been cleaned in accordance with TR19 guidelines, it’s not just a tenant’s issue—it could quickly become yours.
As Technical Director at Plasma Clean Air, I regularly see how important it is to undertake TR19 audits for landlords and operators who want independent assurance that their ductwork cleaning meets the standards set by BESA’s TR19® Grease. Here’s why these audits are essential, what to look for, and how they protect your legal and financial interests.
What Is TR19 and Why Does It Matter?
TR19® is the industry-recognised guidance document produced by the Building Engineering Services Association (BESA). It sets out best practice for ductwork cleaning, particularly in grease extract systems found in commercial kitchens.
TR19 isn’t a legal document in itself, but it is referenced in fire safety guidance and insurance frameworks. That makes it the de facto standard for compliance. If a fire breaks out and it’s discovered that a system wasn’t cleaned to TR19 standards, it can have serious legal implications—for both tenants and landlords.
The latest iteration, TR19® Grease, includes more detailed guidance on post-clean verification and testing, such as wet film thickness (WFT) measurements to assess residual grease. A certificate alone isn’t enough. You need evidence that cleaning was done properly—and that’s where a TR19 audit comes in.
Who Can Carry Out TR19 Cleans and Audits?
Not all cleaning contractors are created equal when it comes to TR19 compliance. To ensure that ductwork cleaning and auditing meets the rigorous standards set out in TR19® Grease, only companies listed on the BESCA Ventilation Hygiene Register (VHR) should be used. This register is managed by the Building Engineering Services Competence Assessment (BESCA) scheme, which ensures that registered firms follow industry best practice and meet the necessary technical competencies.
Even within these registered companies, only trained and accredited Grease Hygiene Technicians (GHTs) are permitted to certify that a clean has been carried out to TR19 standards. That means the report, WFT readings, and before-and-after photographs must be completed and signed off by a qualified technician.
Without this, the documentation may not hold up under insurance scrutiny or a post-incident investigation. When appointing a contractor or auditor, always ask for BESCA VHR registration and the name of the certifying GHT—don’t take compliance on trust.
Why Landlords and Shopping Mall Operators Should Care
If you operate a shopping mall or mixed-use building with food tenants, you may assume that your tenants are handling their own kitchen extract cleaning obligations. But can you be certain that they’re doing it to the right standard?
In the event of a fire:
- Your building insurance may be invalid if the extract system wasn’t cleaned to TR19.
- You could be liable under the Regulatory Reform (Fire Safety) Order 2005.
- Reinstatement costs could run into the hundreds of thousands.
- Reputational damage could affect your wider property portfolio.
So while cleaning may be a tenant’s responsibility under lease agreements, fire risk management remains a shared interest.
What Does a TR19 Audit Involve?
A TR19 audit is a third-party inspection of the grease extract system, carried out independently of the cleaning contractor. It typically includes:
- Visual inspection of the system, including ductwork, canopy, and fans.
- Wet film thickness (WFT) testing to measure residual grease levels.
- Photographic evidence before and after cleaning.
- Compliance scoring against TR19 benchmark levels.
- Recommendations for remedial action if required.
At Plasma Clean Air, we also check whether appropriate access panels are in place, how often the system is cleaned, and whether the existing service schedule aligns with usage levels. A high-traffic food court will need much more frequent cleaning than a small café.
Common Issues Found in TR19 Audits
In our experience, even reputable contractors can fall short of full TR19 compliance. Common issues include:
- Cleaning only the visible parts of the system, such as canopy filters.
- Failure to clean inaccessible ductwork due to missing access panels.
- Inadequate reporting, with no WFT readings or photographic evidence.
- Overly long cleaning intervals that don’t match system usage.
These aren’t minor oversights—they’re fire risks. A single ignition source in an uncleaned duct can spread quickly through the system, especially in a building with multiple food outlets and shared risers.
What Action Should Landlords Take?
If you’re responsible for a retail site, food hall or shopping centre, I recommend the following steps:
- Map your systems: Know which extract systems run through your property, who’s responsible, and where the risks lie.
- Check the paperwork: Don’t just file away TR19 certificates—review the supporting evidence. If it’s not detailed, it may not be compliant.
- Commission independent audits: Bring in a third-party expert to conduct a TR19 audit, especially for high-risk tenancies.
- Align contracts: Ensure tenant leases and service agreements specify compliance with TR19, with audit rights clearly stated.
- Act on findings: Where systems fail to meet TR19 standards, require remedial cleaning and follow-up audits.
Final Thoughts: Don’t Wait for a Fire to Learn Who’s Responsible
TR19 compliance is one of those things that often goes under the radar—until something goes wrong. And in the aftermath of a fire, everyone’s asking the same question: Was it cleaned properly?
By commissioning independent TR19 grease audits, landlords and operators can ensure that kitchen extract systems are not just cleaned, but verified to meet current standards. It’s not just best practice—it’s sound risk management.
If you’re unsure about the compliance status of your building’s kitchen extract systems, get in touch with us at Plasma Clean Air. We offer nationwide TR19 audits, full reporting, and support to help you stay ahead of the fire risk curve.
