COMMON CODE VIOLATIONS AND HOW TO AVOID THEM
When building, remodeling or replacing kitchen equipment, it’s vital to customers that the project stays on schedule. However, with food equipment codes regulated on a national, state and local level, staying up to date can be both a difficult and time-consuming task. With codes frequently changing, it’s necessary for consultants and manufacturers to stay current to avoid delays that can be caused by code violations.
Although keeping abreast of equipment regulations is a challenge, there are commonly occurring conflicts that can be prevented. Asking targeted questions concerning the customer’s facility at the onset of the project can help prevent violations, making the process more efficient and straightforward.
Code violations can occur in the electrical, mechanical and plumbing areas, as well as in other areas of the equipment, with each category representing its own obstacles. Some common code conflicts and ways to avoid them include:
Electrical
Machines Without an Underwriters Laboratories (UL) Mark
Requirement: When orders are placed on specialized equipment (e.g., an extra heater is requested), a UL mark might not be put on the product, as this specific piece of equipment is not typically submitted to UL for Listing. To comply with the National Electrical Code, this piece of equipment must be approved by a certified testing agency or accepted by an authority having jurisdiction (AHJ).
Avoid the violation: If a customer orders a specialized piece of equipment, find out from the manufacturer if the product will bear the UL mark. If not, inform the customer or contractor that he or she will need to have the device site inspected by an independent testing agency (examples include UL, ETL, CSA) if it is not accepted by the AHJ. Oftentimes, customers are unaware of this code and are surprised and upset when they receive the equipment and are unable to use it because it does not have the UL mark.
No Disconnect Switch
Requirement: The National Electrical Code states that there must be a disconnect switch within sight of all appliances if the circuit breaker is not capable of being locked in the open position. Generally, a circuit breaker will be on the wall of the facility, and the breaker can serve as the disconnect switch. If no circuit breaker exists, one can be ordered with the machine to meet code.
Avoid the violation: When a customer is ordering an appliance, ask if the customer has a disconnect switch or a circuit breaker capable of being locked in the open position. If the customer is unsure, speak with the facility’s electrician to obtain this information. If a disconnect switch is needed, inform the manufacturer when ordering the equipment to save time and money.
Mechanical
A Double-Wall Booster Is Needed on Warewasher
Requirement: Any facility that produces non-sanitary steam is required to have a double-wall booster. If a facility is producing clean or culinary steam, only a single-wall booster is needed. The standard steam booster provided by the factory is single wall.
Avoid the violation: When discussing which warewasher to order, ask the customer if the current equipment produces clean steam. If the customer does not know, the facility’s mechanical staff can find out. If the facility is producing clean steam, the boiler will have a sticker indicating that the chemicals meet FDA requirements for food grade. Knowing whether a single- or double-wall booster is needed when placing the order will save customers time and money.
Vent Hood Is Needed on Warewasher or Cooking Appliance
Undercounter or low-temperature dishwasher
Code: Paragraph 6-304.11 of the 2005 FDA FOOD CODE reads, “If necessary to keep rooms free of excessive heat, steam, condensation, vapors, obnoxious odors, smoke, and fumes, mechanical ventilation of sufficient capacity shall be provided.” In addition, the 2006 International Mechanical Code requires a Type II vent hood over appliances that produce heat, steam or products of combustion that do not generate grease or smoke. Currently there is an exception for undercounter dishwashers but not for chemical sanitizing models.
Requirement: The code requirements for vent hoods change frequently. The most recent proposed change is to require Type II hoods over all dishwashers and light-duty appliances, except where the heat or moisture loads are incorporated into the HVAC system design or into the design of a separate removal system.
Avoid the violation: If your customer is using a commercial dishwasher that is configured to operate in the chemical or low-temperature-sanitizing mode, no vent hood is required. A vent hood is not needed because chemical-sanitizing machines operate with a wash and rinse water temperature of approximately 120 to 140 degrees Fahrenheit and therefore do not produce excessive amounts of steam. If the customer has a high-temperature-sanitizing undercounter dishwasher, no hood should be required. In the future, customers might be required to use the factory specifications for latent and sensible heat output from equipment to properly size the HVAC system. If local authorities raise any concerns, always contact the manufacturer for assistance.
Cooking
Requirement: A Type I vent hood over a cooking product must be installed so it automatically turns on when cooking commences either through a heat sensor or interlock, or other “approved” means.
Avoid the violation: When specifying cooking products, ensure all equipment is designed and installed to automatically activate the exhaust fan whenever cooking operations occur.
Plumbing
Drain Water Not to Exceed 140 Degrees
Code: The International Plumbing Code, 2006, paragraph 701.7 reads, “Wastewater when discharged into the building drainage system shall be at a temperature not higher than 140°F (60°C). When higher temperatures exist, approved cooling methods shall be provided.”
Requirement: If water at or above 140 degrees Fahrenheit will be drained in cooking equipment with steamers and warewashers, a drain-water-tempering kit must be installed in the equipment to ensure the water does not soften the plastic piping.
Avoid the violation: Prior to ordering cooking equipment, find out if draining water temperatures will be at or will exceed 140 degrees Fahrenheit. It is easier and more cost efficient to install the drain-water-tempering kit during the installation process rather than to add the kit after the equipment has been installed. If the water temperature is unknown, it is recommended that a measurement be taken. Though the final rinse water temperature on a conveyor dishwasher is 180 degrees Fahrenheit, it cools rapidly when sprayed through the final rinse nozzle and therefore might not exceed 140 degrees Fahrenheit by the time it enters the drain.
An Indirect Drain Is Needed
Code: Section 5-402.11 of the 2005 FDA Food Code reads, “(A) Except as specified in (B) and (C) of this section, direct connection may not exist between the sewage system and a drain originating from equipment in which food, portable equipment or utensils are placed.”
Requirement: Plumbing codes require that when draining the dishwasher into the floor, an indirect drain is needed to prevent water from backing up into the dishwasher should the drain back up. Additionally, if the jurisdiction governing the installation of the machine has adopted the 2003 or newer International Mechanical Code, an indirect drain is required.
Avoid this violation: First, find out if your jurisdiction has adopted the 2003 International Mechanical Code. If so, an indirect drain is required. If the jurisdiction has not adopted this code, determine where the dishwasher will drain. If an indirect drain is needed, inform the customer that an open connection, a special fitting available at plumbing supply stores, will be needed to avoid breaking code. Installing this drain ahead of inspection will save time.
Grease Interceptor Is Needed
Code: Paragraph 1003.3.1 of the 2006 IPC reads, “A grease interceptor or automatic grease-removal device shall be required to receive the drainage from fixtures and equipment with grease-laden waste located in food preparation areas, such as in restaurants, hotel kitchens, hospitals, school kitchens, bars, factory cafeterias and clubs. Fixtures and equipment shall include pot sinks, pre-rinse sinks; soup kettles or similar devices; wok stations; floor drains or sinks into which kettles are drained; automatic hood wash units and dishwashers without pre-rinse sinks. Grease interceptors and automatic grease removal devices shall receive waste only from fixtures and equipment that allow fats, oils or grease to be discharged.”
Requirement: Grease interceptors are required in commercial warewashers when there is not a pre-rinse sink.
Avoid the violation: Determine if there is a pre-rinse sink. If there is no pre-rinse sink, a properly sized grease trap is required on the dishwasher drain. Installing the trap ahead of inspection will save time. If there is a pre-rinse sink, the dishwasher will not need to be connected to the grease trap. However, it’s important to ensure the drain in the pre-rinse sink is connected to a properly sized grease interceptor.
Other
Unless sealed to the floor, all undercounter equipment must be on wheels or skids, allowing customers to wheel it out and clean behind it.
Feeder alarms are required on dishwashers to notify operators when sanitizer or detergents are empty.
The federal government is increasing restrictions on hazardous substances, such as mercury, as well as on electrical and electronic equipment waste. Check with your local jurisdiction for the most up-to-date codes.
For additional information on equipment coding, contact Joel Hipp at Joel.Hipp@HobartCorp.com.
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