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GRANDFATHERING - When is “Old”, too Old?

By: George Zawacki, FCSI,CFSP

When is “old” too old and out-of-date, compared to current standards of equipment design, sanitation and operation? The question came up when UP YOUR STACK®  visited this well cared-for suburban high school kitchen. We did some sleuthing and talked to several people in the building and found one teacher who stated that it had been built about 1952. He told us that the kitchen area was part of the original building which has since been expanded to add additional wings to the school.

We first observed the construction of work tables with their old and obviously repainted galvanized legs. Not surprisingly the stainless steel tops were still in acceptable condition. We then looked at other areas such as the antique cafeteria counters with their angle iron construction that would fail any sanitarian’s certification if had been delivered today. Here the stainless tops had been cut and abused with old holes remaining. Unsanitary gaps existed in many locations.

Remember that in the 1950’s, NSF had only recently started to be recognized by local sanitarians as a tool to enforce good construction methods. NSF began the process of certifying foodservice equipment based on how well it could be cleaned. Before that, any shop could build any equipment however it wanted to.

When we turned our attention to the exhaust system, we really began to ask ourselves about grandfathering. When is “old” too old? Modern methods of design have been encouraged by NSF International since it was founded in 1944. That was 61 years ago. This particular school has been in existence for 53 years and is still using the original kitchen. It is apparent that numerous pieces of operating equipment have been replaced over the years, but the basic equipment such as hoods, serving counters, tables and other fabricated equipment remain as they were built 53 years ago.

Modern sanitation practices have developed over a long period of time. Few of us associated with environmental health would expect any retail establishment or institution to replace its expensive equipment and/or systems when improvements are made. But we do ask the question, “is there a time period that should be mandated to bring operations up to current code requirements?”  We ask this question with a full understanding that budgets are strained at every level of government. “Why fix it, if it ain’t broke?”

Environmental health officials at DuPage County just west of Chicago have decided to take a stance with the issue of grandfathering. Officials at DuPage County handle the plan approvals, and inspections for more than 34 local municipalities including unincorporated areas. Sara Burton-Zick, Chief Plans Examiner tells us that DuPage County decided a few years ago to face the grandfathering issue head-on.

They faced the issue by requiring that each restaurant being extensively remodeled or has been closed and wishes to reopen meet all current and applicable current codes. Some new restaurant operators getting into the business would purchase used equipment and try to pass it off as existing equipment enabling them to use the grandfathering rule. This reality brought the DuPage team to squarely face this issue. Sara states “they now have a firm policy”.

The word is getting out that operators wanting to set up shop in DuPage need to do it right. Sara maintains that it will take a long time, but their policy is beginning to make a difference in the quality of foodservice installations throughout DuPage County. If what NSF International stands for is important, then what DuPage is doing must be considered a best practice.

How can we mandate updates by asking operators to meet current codes? We would like to make the point that many of these “old” facilities are owned and operated by government. Many are terribly inefficient in terms of energy conservation. Government buildings of all types including military installations and school buildings throughout the country are often used well beyond their expected lifetimes. They become out-of-step with current best practices, yet government mandates best practices through their local code enforcement.

So how can anyone expect government officials will fund programs to update facilities? “Why fix it, if it ain’t broke?”

We are reminded every day of excessive spending by government officials from Congress down to the smallest local government entities. Government is on a spending spree at a rate unheralded in our US history. That statement does not take into account the costs associated with the likes of Katrina, Rita and the Iraq war. We now talk about billions of dollars as if it is play money. We frequently talk about college students accumulating excessive credit card debt while the US government is the ultimate example of debt creation.

Back to the kitchen. Since we were visiting this school to observe the exhaust system cleaning, we began to take note of how these hoods were built. For openers, the hood was only 18” high which resulted in the filter bank being placed at a very shallow angle, perhaps 20 degrees allowing grease to fall back over the cooking lineup. Today, that minimum is mandated at a 45 degree angle required by NFPA 96 to protect those who consume the food from contamination.

While the filters originally used were mesh, they had been replaced for the most part by aluminum baffle filters. Well, not quite all of them; there were still were a handful of mesh filters specifically outlawed by current codes. Even then, some of the baffle filters were broken, defeating the purpose of having a filter in the first place. A broken baffle in a filter allows grease laden air to take the path of least resistance and pass directly into the duct and exhaust fan system.

The next item we noted was the height of the hood at about 7’-0” above the floor. While 6’-6” is the normal elevation of most kitchen canopy hoods, it is common practice for various reasons to mount a hood higher, provided the canopy or hood overhang compensates for the higher elevation. This long bank of hoods in excess of 30’-0” has no overhang. None. The front edge of the hood lines up with the front of the range battery. At the convection ovens, it is a classic case of the oven fronts extending far beyond the hood line.

That condition extends to all four sides of the hood. While the back of the hood lines up with the wall behind it, the wall stops short at 6’-6” above the floor creating a 6” gap at the rear. It effectively turns this system into an island canopy without any overhang.

When we stepped behind this cooking line, we found a long line of steam kettles, pressure steamers and the like, all direct vented. Above this lineup, there is no Type II hood to remove all the steam, moisture and heat produced by these devices.

I do not fault the original designers as I cannot put myself in their shoes back in the early 50’s when this facility was designed. They probably did the best they could with the budget constraints and the knowledge of current practices in use back then. But again, I pose the question, when is “old”, too old?

If you have any comments or thoughts on grandfathering, write to us at george@upyourstack.com.


 
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