Interpretation #: CEB-2023-20 [2014 IMC-507.2.1]

Building or Fire Safety Law Interpreted

675 IAC 18-1.6 2014 Indiana Mechanical Code, Section 507.2.1 Type I hoods. Type I hoods shall be installed where cooking appliances produce grease or smoke as a result of the cooking process. Type I hoods shall be installed over medium-duty, heavy-duty and extra-heavy duty cooking appliances. Type I hoods shall be installed over light-duty cooking appliances that produce grease or smoke.

Exceptions:

Issue

Whether Section 507.2.1 of the 2014 Indiana Mechanical Code (IMC) requires a Type I hood at a self-contained cooking appliance located at the dining table of a retail food service establishment.

Interpretation of the State Building Commissioner

Yes, section 507.2.1 of the 2014 IMC does require a Type I hood at a self-contained cooking appliance located at the dining table of a food service establishment if the appliance and its use conform to the characteristics identified in the section, and if the appliance does not qualify for either of the section's stated exceptions.

Rationale

The language of Section 507.2.1 of the 2014 IMC is relatively straightforward and not subject to differing views as to its meaning, and the interpretation provided above reflects this. Simply put, the hood requirement is tied to the type and use of the device, and to whether the device qualifies for one of the stated exceptions. Nevertheless, the question of what device does or does not require a Type I hood arises with enough frequency that it is instructive to examine the criteria that contribute to the answer in any given case.

The section contains three declarative statements of conditions in which a Type I hood is required:

• Where cooking appliances produce grease or smoke as a result of the cooking process.

• Over medium-duty, heavy-duty and extra-heavy duty cooking appliances.

• Over light-duty cooking appliances that produce grease or smoke.

If any one of these conditions is present, the code requires a Type I hood be installed at the device, subject to exemption by the section's exceptions. The last two of the conditions refer to specific code-defined categories of cooking appliances.¹

If the building official is unsure how a given cooking device is categorized, it is worth the official's time to examine those definitions. They can clarify which, if any, of the three conditions in the requirement apply to the device. It is not necessary to this interpretation to reproduce those definitions here, but it is worth noting that none of them are stated as all-inclusive appliance lists. Rather, they state the types of appliances each category contains. The building official must determine in which category a device belongs based on whether it performs cooking of the type, scale, or intensity of the other appliances named.

The section's Type I hood requirement statement is followed by two specific exceptions. Exception 1 exempts the device from the requirement for the hood if the device is demonstrated by a testing agency to comply with a specific performance requirement for limiting the passage of grease-containing effluent when tested in accordance with criteria contained in Section 17 of UL710B. There is no requirement that the testing be performed by Underwriters Laboratories, nor that the device carry a UL710B label. The only requirement is that the device pass the specific performance test identified. If the device meets that performance requirement, there is no requirement that it be equipped with a Type I hood. Exception 2 is for a specific type of pizza oven, exempted from the hood requirement if it is not used for the cooking of certain raw fatty proteins.

Note that this interpretation does not state categorically that the device in question requires a Type I hood, only that under Section 507.2.1 it requires one if the device meets the cooking characteristics of that section, and if it does not qualify for one of the section's exceptions. The interpretation process is solely for the clarification of meaning or intent of a building law. It is not for finding of facts, including determining whether a given cooking device requires a Type I hood, or whether that device's test results meet the performance requirements for exemption by exception. It remains the responsibility of the building official to determine the answers to these questions, as well as to determine whether an appliance exempted from Type I hood requirements does or does not require a Type II hood.

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¹ In addition to the information contained in Section 507.2.1 and the cooking appliance definitions, further clarification on the question Type I hoods can be obtained in Table 507.2, which is not examined as part of this interpretation request.