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September 15, 2009

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Kitchen confidential

Risks and hazards abound in the busy, hot and confined space that is the average commercial kitchen, and the sources for many of these are the myriad gas and electrical systems and appliances necessary for running large-scale catering operations. Here, Bernard Patrick outlines the regulations and standards governing such equipment, and suggests how practitioners can ensure compliance.

Commercial kitchens constitute a fairly hazardous working environment, one in which there is great potential for misunderstanding the legal requirements of the relevant standards governing such premises. All gas and electrical equipment must conform to these standards, and also perform under the exacting requirements of busy kitchen life.

Failure to do so can be costly; witness the Derbyshire pub landlord who, last December, was fined £32,000 over a filthy and unsafe kitchen. The offences included a breach of reg.35(3) of the Gas Safety (Installation and Use) Regulations 1998 (GSIUR) by failing to ensure a gas supply is checked at least once every 12 months, and records kept.

Gas safety
With regard to gas-burning appliances, BS6173:2001 is the current standard, which must be applied in conjunction with the GSIUR. The HSE’s interpretation of both is outlined in its Information Sheet 23, ‘Gas safety in catering and hospitality’.1 Additional information relating to ventilation, obviously an important part of gas safety, is contained in Information Sheet 10, ‘Ventilation of kitchens in catering establishments’.2

The main requirements of the GSIUR in commercial kitchens are:

  • Regulation 35, which requires employers to ensure that gas appliances, flues, pipe work and safety devices are maintained in a safe condition. They should be inspected by a competent person, in accordance with current industry practice. Periods between inspections may vary, depending on the equipment and its use, and should follow the manufacturer’s recommendations but, as a general rule, annual inspections will be a reasonable minimum frequency; and
  • Regulation 27(4), which requires theprovision of an interlock, which will shut off the gas supply to such an appliance in the event of an air-movement failure.

The main requirements of BS6173:2001 are:

  • Flame supervision: All new enclosed burner appliances (e.g. ovens) should be fitted with a flame failure device’ (FFD), whereas there is no requirement for FFD on gas hobs and the like. In kitchens using non-FFD appliances a gas tightness (or proving) control must be used. This type of control tests the gas system not only for leaks from unsupervised appliances but also leakage problems in the system as a whole;
  • Gas supply isolation: each fixed appliance should have a single manual means of isolation for servicing or cleaning purposes;
  • Sufficient ventilation for the number and type of appliances; and
  • Interlocking of the gas supply with the ventilation system.

Because of the prime importance of ventilation, BS6173 requires that before using gas appliances the effectiveness of the ventilation is tested and proved to be working correctly. Should the test fail, then the interlock control will prevent the gas supply from being turned on. Similarly, should the ventilation fail while the gas supply is on, then the interlock will shut off the supply.

3

No registered gas engineer (Gas Safe-registered, formerly CORGI) would install a new gas appliance that does not have a certificate proving its compliance. Under the CE marking scheme gas appliances are one of the areas (as well as the automotive, drugs and aviation industries) that have special requirements in relation to legal display of the mark. Independent gas-burner components and controls, such as flame failure devices, gas safety shut-off valves, and gas-leakage controls, are required to have a certificate of compliance to the appropriate standard issued by a NAMAS-accredited4 laboratory. CE marking of these parts without the NAMAS validation and certification is illegal.

Generally, most certified gas appliances will be built using suitable and independently approved components. In any event, the certificating laboratory will check that all components used are suitable for purpose before testing a new appliance. Broadly speaking, for an appliance to be totally safe the gas must be burned cleanly, it must light up without exploding, and the cooking temperatures must be adequate, while the external surface temperatures should not be hazardously high.

Unlike the majority of electrical appliances and components, any certified gas appliance, or major component, will have been tested and certified to the current electrical standards. Its suitability for purpose will have been verified and its manufacturer will have been regularly inspected.

For this reason, gas appliances in the UK are better made and are safer with regard to their electrical requirements than their run-of-the-mill, purely electrical counterparts. This is also likely to be true of their actual physical installation; gas installers in the UK generally understand the need to install properly sourced and certified – and therefore safe – equipment. It is important to bear in mind, however, that even though the gas appliance or component has been tested and certified to ensure complete safety it can be rendered unsafe if used in conjunction with electrical components developed outside of the gas ‘safety net’ described above.

Electrical safety
All the normal rules of electrical safety apply in commercial kitchens, but even more so! Nevertheless, many electrical kitchen appliances, as well as basic items of electrical switchgear used to control them, lack the most basic requirements, such as CE marking.

There is still nothing approaching the Gas Safe Register for electrical installation work, meaning electrical components that would never be accepted as an integral part of a gas appliance, as explained above, are commonly installed. The likes of fan-motor speed controllers, food-warming lamps, and ventilation interlocks, as well as a plethora of non-compliant electrical kitchen appliances, are often found installed without any consideration of electrical safety requirements.

Indeed, many UK electrical manufacturers don’t seem to observe the CE, IP or EMC marking requirements on anything like the same level as their European counterparts. In my experience, German, Dutch, Scandinavian and Italian manufacturers are fastidious in observing the CE scheme.

Kitchens, and especially commercial ones, are wet-work environments but protection for operators with wet hands and clothing from electric shock is often inadequate, and sometimes non-existent. So, in addition to testing and compliance-marking of all electrical controls and appliances extra protection is required in the harsh kitchen environment.

Standard EN 60529 outlines an international classification system for the effectiveness of electrical equipment in withstanding the ingress of foreign bodies (e.g. dust) and moisture. This is known as the ‘Ingress Protection’, or IP classification system. While not required by law, all mains-voltage, commercial-kitchen electrical equipment should be rated to a minimum of IP65, which means that all seals are dust-tight and can withstand water projected from a nozzle. This rating allows for all normal catering hygiene operations while also providing a high level of protection against electric shock.

Food for thought
To determine whether or not a commercial kitchen premises complies with the above-mentioned laws, standards, and other requirements, the following should be examined:

Gas supply, gas valves and system
The gas meter and internal pipe work must be adequate to meet the highest demand. For an interlock and proving control to work, an automatic gas valve is required. The valve should be ‘normally closed’ and is also referred to as a Safety Shut-Off Valve (SSOV).

The gas installation as a whole should be inspected at least annually (or more often, in busy kitchens) by a ‘competent person’, namely a Gas Safe (formerly CORGI) registered engineer. This assessment should include the ventilation systems and controls. Note that it is this person alone (not their corporate identity) who is solely responsible for assessing the compliance and therefore safety of the kitchen.

Gas appliances
All appliances should be CE-marked (as discussed above) and usually indicate testing and compliance with the relevant standard – for example, EN161 for gas valves. Often, the NAMAS laboratory and certificate number is shown, which can be checked with the named certification body.

Mechanical ventilation
The extraction rate is best calculated from the information supplied with the appliances themselves – for example, a salamander-type grill requires a ventilation rate of 17 cubic metres a minute. It should also take account of air-change rates required for kitchens.

Controls
As BS6173:2001 and the GSIUR require that the supply of gas is directly linked to the ventilation supply, a fan safeguard or interlock control has to be installed in new or upgraded kitchens. An interlock will test whether the ventilation is adequate before allowing the gas to be turned on, and then continue checking for as long as the gas is on.

In the unlikely event that existing kitchens have not been updated to meet this requirement the standard is not retrospective. In these cases, if the kitchen is still in operation, a competent gas engineer will have issued a ‘Not to Current Standards’ (NCS) notice, having assessed that the current working practices, ventilation, etc. are adequate.

Although now proscribed by the HSE, some older installations may have an interlock fitted with a manual override. Obviously, this type of system is also NCS and could be considered dangerous if the override was used to circumvent the need for regular maintenance of the ventilation system.

To prevent the gas supply from being turned on inadvertently when appliances without FFD have been left on, a gas-tightness or proving control to test for gas leakage should also be installed. Even in ‘FFD appliance only’ installations a gas tightness check will indicate system integrity and is therefore an important additional safeguard.

Emergency gas isolation switches can be linked to the gas-proving control using a compliant switch, which must be shrouded and correctly labelled as such.

Unlike gas appliances, it is not currently compulsory to have these controls independently certified as compliant by a NAMAS-approved laboratory. Indeed, there is a case to say that these controls are, in fact, gas appliances and therefore should be tested and marked. Very few of the currently available controls have been tested or marked in this way, so they would ideally need revision before gaining certification.

Lastly, all control equipment, including sensors and switches, should have appropriate labelling, starting with the CE mark. By affixing the latter, the manufacturer – or, in certain cases, another legal person responsible for the product – asserts that the item meets all the essential health and safety requirements of the relevant European directive(s) that provide for the CE marking.

Any electrical product legitimately bearing the CE mark must also show the following, so-called ‘declared’ information:

  • Thesupply voltage, the frequency, and the power consumption;
  • Statutory warnings to the effect of ‘This is a safety device – do not tamper’;

    and

  • Statutory warnings to the effect of ‘Danger: live terminals – isolate before removing cover or opening’ if mains voltages are in use.

Worryingly, much ofthis type of equipment is fitted without any of this basic safety labelling.


Sensors and switches
The final, and perhaps most critical, part of the interlock system is the device that tells the control the ventilation system is operating correctly – the sensor or switch. The best way to test the ventilation is to directly measure the volumetric flow of air. The simplest method is to check for a pressure differential in the ventilation ductwork using a mechanical diaphragm pressure switch. Because this method is more difficult to set up, installers tend to favour using the indirect method of sensing whether the ventilation fan motor is drawing power. While this is a valid method, if set up incorrectly or inappropriately, it does not necessarily indicate air flow, as flues may be blocked, drive belts broken, etc.

Training and competence
Often overlooked, or left out for cost reasons, but absolutely essential is sufficient staff training to ensure correct operation of all the safety equipment. It is pointless installing state-of-the-art equipment if the staff using it don’t have the knowledge not only to operate it safely but also how to act in any safety-critical situation.

Summary
Commercial kitchens can be just as dangerous a place to work as any building site or factory, especially in these times when employers, clients and premises owners are looking to make cost savings wherever they can. To avoid health and safety becoming a casualty of the credit crunch practitioners working in, or with responsibility for, commercial kitchen premises should ensure equipment and systems comply with both gas and electrical safety regulations, that they come with a clear statement of conformity, and are independently certified. To further protect staff, all electrical equipment should show clear and relevant hazard warnings.   

References
1  www.hse.gov.uk/pubns/cais23.pdf
2  www.hse.gov.uk/pubns/cais10.pdf
3  Note that the Ductwork Group of the Heating & Ventilation Contractors Association (HVCA) has created a detailed specification for kitchen ventilation, entitled ‘DW/172 Specification for Kitchen Ventilation Systems’ – www.hvca.org.uk
4  National Accreditation of Measurement and Sampling

Bernard Patrick is managing director of Caledonian Control Technology Ltd.

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