Current Tag, Invalid Protection: The Unpermitted Charcoal Charbroiler
A 120-seat restaurant in a strip mall has generated three smoke complaints in two months, so the inspector arrives during the dinner rush. Under the Type I hood are a gas range and a deep fryer that appear on the original 2016 plans, plus a charcoal charbroiler the owner added eight months ago without a permit. The hood's wet chemical suppression system carries a current service tag dated three weeks ago. The fusible link above the charbroiler has been painted over with silver hood coating during cleaning; the link above the fryer is clean and legible. The manual pull station sits behind a rolling rack of clean dish trays. A 20-lb ABC dry chemical extinguisher hangs where a class K extinguisher was listed on the last inspection report; the K extinguisher is not in the building. The suppression system's gas solenoid shuts off the range and the fryer, but the charbroiler was tied in downstream of the solenoid with its own manual ball valve. Duct cleaning records exist through last year, make-up air is running, and the hood filters are in place and clean.
1. Define the correct scope of any shutdown order. Should the whole kitchen close, or only part of it, and on what basis?
Read the worked answer
The scope of a shutdown is set by what the protection actually covers, not by which appliance generated the complaint.
The charbroiler is a solid-fuel appliance added without a permit, installed under a hood and suppression system designed and listed for gas and grease. Codes require solid-fuel cooking to be protected by a system listed for that application; a wet chemical grease system is not. Compounding it, the fusible link over the charbroiler is painted, so its listed operating temperature cannot be relied on, and the charbroiler is piped downstream of the gas solenoid, so even a correct system activation would not shut off its fuel. Any one of those justifies taking the charbroiler out of service.
The gas range and fryer stand differently. Their link is clean and legible and the solenoid shuts them down. The defects that touch them are the obstructed manual pull station and the missing class K extinguisher, both correctable the same day.
So the order is partial: red-tag or decommission the charbroiler, prohibit its use, and require the hood, the suppression system, and the fuel shutoff to be brought into compliance under a permit with a listing evaluation. Allow the range and fryer to continue once the pull station is cleared and a tagged class K extinguisher is mounted. Give the owner written notice that the whole-hood design will need re-evaluation once the charbroiler is addressed, because the addition may have invalidated the original system design.
2. The owner points to the three-week-old service tag as proof of compliance. Explain why the tag does not establish compliance and what you would verify yourself.
Read the worked answer
A tag proves a contractor visited; it does not prove the system will work.
The service report is the contractor's statement about the tests it ran within its own scope, and that scope plainly did not include an unpermitted appliance tied in downstream of the fuel shutoff. Inspectors verify rather than accept:
- Fusible links and thermal detectors: correct temperature rating and location for each appliance, unpainted, not substituted with a different rating, and not buried in grease.
- Manual actuation: pull station accessible and unobstructed, correct mounting height, cable free and connected.
- Automatic fuel shutoff: verify by test at each appliance that activation closes the gas valve and de-energizes electric cooking equipment - the charbroiler fails this today.
- Agent quantity and cylinder date, piping condition, and nozzle caps in place and aimed at the appliances actually installed.
- Alarm interface, if the system is tied to the building fire alarm, and the posted system placard.
Also check the servicing company's license and whether the tag date corresponds to a real visit. Record each item as pass or fail against the equipment present, not against the plans. A partial pass is a legitimate finding, and it is exactly what supports a partial shutdown instead of closing the restaurant.