Written by Richard Norman Managing Director of Indepth Hygiene Services Limited 2011/12To comply with legal and insurance requirements - "Ventilation systems must be cleaned" There has never been a previous time when those responsible for the maintenance of buildings and care for the welfare and safety of building occupants had more reason to ensure that ventilation ductwork is cleaned regularly.
In spite of clear regulatory compliance requirements having been in place for some time, there are still far too many buildings where management has failed to meet its legal obligations. It’s probably worth re-stating just what legal requirements are in place governing the procedures and practices to be followed by those responsible for the safety and welfare of building occupants.
To start with the Regulations dealing with the provision and maintenance of safe, healthy and comfortable conditions in the workplace.
These can be summarised:
Workplace (Health, Safety and Welfare) Regulations 1992
Regulation 5 applies to the maintenance of workplace equipment devices and systems and specifically to mechanical ventilation systems which are required to be maintained, including cleaning as appropriate.
Regulation 6 requires that effective and suitable provision shall be made to ensure that every enclosed workplace is ventilated by a sufficient quantity of fresh or purified air.
ACOP33 of Regulation 6 states “Mechanical ventilation systems (including air conditioning systems) should be regularly and properly cleaned, tested and maintained to ensure they are kept clean and free from anything that may contaminate the air”.
It is not unreasonable to ask why in the face of these specific legal requirements so few systems will be found to comply with the Regulations? Maybe a clue lies in the belief that having a ventilation maintenance contract in place will provide sufficient compliance. Unfortunately this is not so. Typically a service contract, whether carried out six monthly or annually, will consist primarily of AHU maintenance e.g. changing the primary filters, checking drive belts in fan motor bearings, checking condenser trays and run offs, cleaning the coils as necessary and checking the volume control dampers. On the occasions when inspections of the internal surfaces of the ducting are carried out this will invariably be only a visual inspection with no measurements made of the degree of contamination or the constituents of the contamination.
In hospitals, where detailed research has been carried out on the role ventilation systems can play in the spread of infection, most notably MRSA, it has been found that duct surface contaminants contain human skin and hair particles which, allied to the typical temperature and humidity levels prevailing in those systems, provides ideal conditions for the development of micro-organisms, which of course can then be disseminated into the ambient atmosphere.
Whilst concerns about MRSA, for example, are not applicable to ventilation systems in the workplace, there are undoubtedly parallels. Contaminants accumulate on internal surfaces of ducting in the same way and unless removed by cleaning will assist the spread of common infections such as colds and flu.
To comply with the Management of Health and Safety at Work Regulations 1999 every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they might be exposed whilst at work. The Health and Safety Executive’s guidance booklet HSG202 which deals with general ventilation in the workplace states “As a general rule, if you run your finger along the opening of a duct and it collects dust it probably needs cleaning”. Both the HVCA (Heating & Ventilating Contractors’ Association) and CIBSE (the Chartered Institute of Building Service Engineers) provide information on testing for likely contaminants in ductwork and on cleaning.
Fire Dangers in Extract Ducting Systems
In recent months Fire and Rescue Services have reported a spate of fires in catering and food preparation establishments where the fire has become widespread and destructive because grease deposits in uncleaned extract ducting had ignited. A good example of what can happen was a major fire at a restaurant in London’s Liverpool Street station. The fire, which had started in the cooking area, travelled into the extract ventilation ducting where grease deposits on the ducting surfaces ignited and aided its spread. Fortunately the building was quickly evacuated and nobody was injured.
Such a fire would have posed serious evacuation problems in a multi-tenanted building. It showed what can happen when a spark or flame from the cooking units finds flammable grease deposits in the extract ducting. The Fire Authorities are well aware of the potential danger of uncleaned extract ducting. A spokesman has stated “uncleaned grease extract ventilation systems present probably the greatest fire risk to building occupants in premises with catering facilities”.
Legally Required Compliance
The Fire Safety Order (the Regulatory Reform [Fire Safety] Order 2005) makes compliance requirements quite clear. Any potential fire hazard that might put occupants at risk must be included in the premises’ fire risk assessments, and action taken to eliminate, or at the very least, minimise the risk.
Why then are these potentially high fire risk installations so often overlooked? The person drawing up the fire risk assessments –defined as the ‘responsible person’ under the terms of the legislation – often does not give the catering unit detailed attention. Sometimes this is because the catering has been contracted out and it is thought the Caterer has responsibility. Not so under the law. The ‘responsible person’ has the responsibility for identifying all potential risks to the lives of building occupants and taking appropriate action. Where the ‘responsible person’ does include the catering unit in the fire risk assessments he may overlook the grease extract ducting because so often it runs out of sight from the kitchen canopy behind walls and ceilings.
Another possible reason for the extract system not being included was highlighted by the recent Competency Commission’s investigation into the level of competency of independent fire risk assessors or consultants. They found an unacceptably high level of incompetence or inadequate services. Again, whether or not an outside consultant is used, the responsible person cannot deflect responsibility for the quality of the fire risk assessments. Poor quality fire risk assessments equal poor protection of occupants’ lives.
Property Insurance Requirements
As a result of increasing numbers of claims, property insurers, including majors such as Aviva, Zurich, Liverpool Victoria and AXA have inserted in their policy as a ‘condition precedent to liability’: “All extraction systems including flues, canopy hoods, extraction motors and the entire length of any extract ducting shall be cleaned”.
In other words, if there is a fire which involves the extract ducting because flammable grease deposits have not been removed from internal surfaces of ducting any claim for loss or damages will be refused. It is no longer sufficient for managers and owners to accept the assurance of a cleaning contractor that the system has been cleaned. They need to check that it has been cleaned in its entirety and the best way to do this is to check whether access panels have been installed in the extract ducting to allow full access for cleaning the entire length of the ductwork. Invariably no access panels means inadequate cleaning.
For the cleaning of extract ductwork systems it is essential to appoint a contractor who will undertake to carry out the work in accordance with the industry standard of excellence – HVCA TR19 published by the Heating & Ventilating Contractors’ Association. This sets out the standard of cleaning and validation to ensure that the system is safe.
About the author
Richard Norman is Managing Director of Indepth Hygiene Services Limited, the UK’s No. 1 company for specialist cleaning of ventilation systems.
For further information on ventilation system cleaning call Indepth Hygiene Services
on 020 8661 7888
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