SAIS Hygiene · Compliance

Who Is a “Competent Person” for Monthly Kitchen Exhaust Inspections?

What AS 1851 actually requires, and the landlord misunderstanding catching out multi-site operators.

By Mark Poole, Managing Director, SAIS Hygiene

Since the NSW fire-safety reforms took effect in February 2025, we’ve seen a recurring point of friction play out across the market, and the same issue applies in South Australia and other state frameworks that lean on AS 1851. If you operate across multiple sites, it’s worth understanding before it lands on your desk.

Two misreadings of the new regime keep coming up:

That kitchen exhaust systems now require monthly cleaning regardless of cooking type, with some landlords pushing that cost onto tenants.
That monthly inspections must be carried out by a “competent person” under AS 1851, and that store staff can’t meet that test.

The second one is the bigger trap, and it’s where operators are being pressured unnecessarily. Here’s our read.

What AS 1851 actually requires

AS 1851 Clause 13.4.1.16 calls for a monthly inspection of the system: checking the filters, hood, plenum and grease gutters for excessive grease accumulation.

What the clause does not do is specify who has to perform that inspection, beyond Clause 1.10’s general requirement that it be done by a “competent person.” That distinction matters.

The “competent person” misunderstanding

Here’s the part that trips people up: there is no AQF-accredited qualification for the routine servicing of kitchen exhaust systems in Australia, and no national licensing scheme. We confirmed this position directly with the Fire Protection Association Australia (FPA Australia) in late 2024, and it is not known to have changed.

So the standard requires a competent person, but it deliberately leaves the demonstration of competence open. Pairing “competent person” with the monthly inspection in a way that excludes trained store staff is, in our reading, erroneous. The practical position we take, and the one generally adopted across the industry, is this:

Monthly visual inspections can be performed by store staff who have been trained and given a clear, documented procedure (a checklist). Competence is demonstrated through training and documented process, not by holding a qualification that does not exist.

That isn’t a loophole. It’s how the standard is designed to work in practice.

Why this matters most for multi-site operators

If you run a single site, this is a conversation. If you run 20, 50 or 200 sites, it’s a portfolio-wide cost and risk exposure, and exactly the kind of pressure landlords apply across a tenancy base.

The operators who handle it best aren’t the ones who argue clause numbers. They’re the ones who can produce, on request, the evidence that a competent monthly inspection process is actually running across every site.

How to get ahead of it

The thing to do now is to document your internal process around monthly inspections, so that when a landlord pushes, you have the package that demonstrates competence and process. Specifically:

A training piece for store managers on what to look for, especially what “excessive grease accumulation” actually looks like.
A simple monthly checklist covering filters, hood, plenum and grease gutters.
A record-keeping process: under the new regime, AS 1851 records need to be kept on-site for seven years.
Evidence the inspections are actually being done: completed, dated checklists, not just an intention.

When the conversation comes, that package is what carries it. Without it, the conversation is harder.

An important caveat

This is our interpretation of the standard, based on how it has been applied in practice and our correspondence with FPA Australia. For a formal position across a large portfolio, particularly if you’re facing specific landlord scrutiny, you may want a fire engineer to sign it off.

What we can do is make sure the cleaning side of your obligations is handled properly, documented to standard, and backed by photographic evidence you can produce when someone asks the hard question.

Frequently asked questions

Who can perform monthly kitchen exhaust inspections under AS 1851?

A competent person, as required by Clause 1.10. The standard doesn’t define this as a specific qualification, because none exists for routine kitchen exhaust servicing in Australia. In practice, a trained staff member working to a documented checklist can perform the monthly visual inspection.

Does AS 1851 require monthly cleaning of the exhaust system?

No. Clause 13.4.1.16 requires monthly inspection. Cleaning frequency is generally determined by cooking type and grease load — a high-output kitchen needs cleaning far more often than a light-use one.

Is there a qualification or licence for kitchen exhaust inspection in Australia?

No. There is no AQF-accredited qualification and no national licensing scheme for routine kitchen exhaust servicing, a position we confirmed with FPA Australia. Competence is demonstrated through training and documented procedure.

How long do AS 1851 records need to be kept?

Under the current regime, records should be kept on-site for seven years.

What should a multi-site operator have in place?

A store-manager training piece, a monthly inspection checklist (filters, hood, plenum, grease gutters), a record-keeping process, and evidence that inspections are being completed across every site.

Not sure whether your current arrangement gives you the documented evidence you would need if someone asked? SAIS Hygiene cleans, documents and photographs commercial kitchen exhaust systems to AS 1851-2012 across more than 1,000 sites nationally.

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