19-1211 v3.X Clarification on Dedicated Exhaust for Kitchens

Question

Our building is a multi-tenanted retail centre. Our intent is to improve occupant health by reducing or eliminating indoor pollutants, and as such, part of our Healthy Indoor Environment Plan is to ensure there is exhaust for kitchens, bathrooms and janitorial areas, as required under the Healthy Interior Environment imperative. Of specific interest to us in this dialogue post is for “front-of-house” areas. This might be, for example, a café servery area with food on display, a coffee machine, a sandwich toaster, and a place for a customer to pay. These front-of-house areas, without mechanical exhausts, have little-to-no negative impact on air quality. We have verified this by undertaking an air quality test in an equivalent food tenancy already in operation. Indoor pollutants were not detected.
Conversely, every back-of-house commercial kitchen in our building has been provided with dedicated exhaust. We have also made this an ongoing requirement in our fitout guide for future tenants too. These front-of-house areas do not have a dedicated exhaust immediately above. There are three reasons for this:
1. For the purposes of this imperative, we understand the definition of “kitchen” as an area that has exposed cooking, i.e. a pot or frying pan on a stove.
2. We have reviewed other LBC and non LBC projects with similar arrangements, and have yet to find any that have dedicated exhaust in these front-of-house kitchen areas.
3. All front-of-house spaces in our building have direct access to natural ventilation.
We believe we are compliant with the requirements of the imperative, but for clarity, wish to confirm our understanding is correct.

Answer

Your assumptions are correct; the cafe servery and food display areas are not considered kitchens, and therefore do not require separate exhaust. However, any commercial kitchens in the building must have dedicated exhaust.

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