Canadian Underwriter

Cooking Up Restaurant Insurance

July 1, 2006   by Larry Watson, Director of Loss Control, ING Canada

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Cooking with fire is always a double-edged sword. If contained, fire can provide warmth, comfort and great food! If allowed to escape, fire can cause personal injury, destroy property and adversely affect the prosperity of insurers and restaurateurs alike.

In order to manage their restaurant business, insurance companies and brokers need to understand changes made more than a decade ago to commercial fire protection. A benchmark in the standardized testing of fire suppression systems, the ULC / ORD-C1254.6-1995 will be 11 years old in July 2006. Some insurers however, are still grappling with how to consistently apply it to underwriting.


ULC stands for “Underwriters’s Laboratories of Canada.” It is an accredited testing and certification organization with diverse capabilities. The American equivalent, UL, stands for “Underwriter’s Laboratories.” The presence of a ULC or UL label on a product is an assurance that the product has been tested to a standard. Manufacturers of fire protection equipment will almost without exception submit their products to ULC or UL to be tested, labelled and listed.

‘UL 300’ is a benchmark used in the standardized testing of fire suppression systems that are submitted by manufacturers for use in commercial cooking environments. A revision of the testing procedures used to assess fire suppression systems has resulted in a standard referred to as “the new UL 300.”

The new UL 300 was established in November 1994. What were the dynamics leading up to these changes?


Changes made to commercial cooking operations diminished the effectiveness of fire suppression systems that were previously available on the market. These changes were in response to a climate where agendas of personal health and energy conservation motivated decisions that people made:

* Animal fats used in frying have been replaced with vegetable oils, which lower fat content and cholesterol levels.

* Vegetable oils are healthier than animal fats, but they burn at higher temperatures and therefore generate fires that are more difficult to extinguish.

* Restaurateurs use highly insulated and energy-efficient deep fat fryers to reduce fuel consumption and improve cooking. These fryers maintain their heat much longer than their predecessors making fire extinguishment more difficult.

When existing wet and dry chemical fixed extinguishing systems were tested using the criteria of the new UL 300, they all failed the re-ignition test. Despite their abilities to put out test fires, none of them could secure the fire for the specified amount of time. Insulated fryers using vegetable oils made cooling very difficult and so it was decided to increase the amount of extinguishing agent used prior to testing the systems again. In the end, only wet chemical systems could knock down test fires and pass the re-ignition component of the new UL 300.

The new UL 300 test procedures affected fryers, grills, ranges, char-broilers and woks. Protection associated with the plenum, hood, ducts, chain broilers, upright broilers, and appliances utilizing charcoal and mesquite remained unaffected.

Although dry chemical systems could knock down test fires under the new UL 300, they failed the re-ignition test. To date, no dry chemical systems meet the criteria of new UL 300; as such, they are no longer options for restaurant protection. There are still many dry chemical systems in use, but there were no new installations after July 1, 1995.

In the United States, the effective date of the new UL 300 was Nov. 21, 1994. On Jan. 25, 1995, ULC followed with a directive labelled Certification Bulletin 95-1, accompanied by the first edition of ULC / ORD-C1254.6-1995 (ORD meaning Other Recognized Document). The effective date in Canada was July 1, 1995.

The testing procedure is officially called the ULC / ORD-1254.6-1995 in Canada but it is commonly referred to as the UL 300, which is its American counterpart.


All fire protection systems for commercial cooking applications submitted for testing by manufacturers must be tested using the new criteria in order to be approved and listed by ULC. Systems that meet the new criteria are described as UL 300 systems in the fire protection industry.

Existing fire protection systems must be upgraded to comply with the new requirements of the ULC / ORD-C1254.6-1995 in order to be listed by ULC. Even though the system was ULC-listed prior to 1995, gaps in the protection afforded must be identified and upgrades made in order to qualify it as a UL 300 system under the new criteria.

Existing wet chemical systems can be upgraded to UL 300 standards with minimal expense in most cases. Dry chemical systems cannot be upgraded to meet the criteria of the new standard because they were unable to pass the re-ignition test.

Systems installed in Canada prior to July 1, 1995 are referred to as pre-UL 300 or unlisted systems. Even in the absence of upgrades, these systems will maintain the original listings that were granted to them before the testing and certification demands of the new UL 300.

When the ULC / ORD-C1254.6-1995 was introduced, there was a lot of dialogue as to how it should be interpreted and applied. Some insurance companies issued directives targeting dry chemical systems because they did not meet the criteria of the UL 300 standard; in the process, they did not recognize that wet chemical systems installed prior to July 1, 1995 also did not meet the criteria of this standard.

It is not possible, nor is it the intention of this writer, to speak for municipal fire services, manufacturers, service contractors or insurers in this article. It is possible, however, to create awareness and to bring forward approaches that are available to insurers.


Approach 1

Only applicable to insured restaurants equipped with systems listed under the new UL 300.

Some municipal fire services, insurers, and service contractors require that all commercial cooking operations be equipped with fire suppression systems meeting the requirements of ULC / ORD-C1254.6-1995. Recommendations to upgrade non-compliant systems should be made at the expense of the insured. To be listed under the new standard, the system would have to be installed after July 1, 1995, thereby automatically qualifying it as a UL 300 system. Systems installed prior to this date would only qualify as UL 300 systems after being subjected to the necessary upgrades.

Some provinces in Canada are taking steps to revise their fire codes in order to make the upgrading of all fixed extinguishing systems to UL 300 standards mandatory.

Approach 2

Accepts systems installed prior to July1, 1995, but subject to the following criteria:

* There are no replacement cylinders, nozzles, or major components added, replaced or changed

* There are no extensions to the hood system

* There is no reconfiguration of the appliances

* There is no reconfiguration of the exhaust system

* The system does not deviate from the criteria of the NFPA 96 Standard for Ventilation Control and Fire Protection Cooking Operations.


Approach 2 is softer than Approach 1. Nevertheless, although Approach 2 advises accepting dry chemical systems, the de-listing of these systems has diminished the level of technical support available to them. It should be noted dry chemical systems installed close to July 1, 1995 will be subject to hydrostatic testing by July 1, 2007. In the absence of support from service contractors and manufacturers, the arrival of this date could cause dry chemical systems to lose their listings. That’s because only the dry chemical powder re
commended by the manufacturer can be used for any specific dry chemical system.

Wet chemical systems must also be hydrostatically tested at intervals not exceeding 12 years. The chances of these systems maintaining their listing is greater than that of their dry chemical counterparts because wet chemical is still a viable technology and support is still available in most cases.

Insurers, brokers and their clients should beware of service contractors who are prepared to service and tag non-compliant systems.

Insurance companies are encouraged to manage their restaurant business on a consistent basis through an understanding of the UL 300 and the implementation of best practices. Technical support and value added service should be provided to broker partners and clients in order to establish effective fire protection that is aligned with the approach chosen by the insurance company. Bon appetit!


* Understand the changes introduced by the new UL 300 standard.

* Be consistent and communicate your approach to underwriters and broker partners.

* Ensure that all fixed extinguishing systems are serviced and tagged on a semi-annual basis to ensure reliability and proper working order.

* Develop a restaurant pre-screening form and make it available to your broker partners to ensure that all new restaurant submissions and renewals include the name and telephone number of the contractor who is servicing the system.

* Verify that the system is serviced on a semi-annual basis, is compliant and can be supported by the contractor. Note that out of respect for privacy, some service contactors will require permission from the insured prior to releasing information.

* Pre-screening forms should include the name and telephone number of the contractor who is cleaning the exhaust and ventilation ducts.

* Contact the servicing contractor to verify that the exhaust and ventilation ducts are inspected as per the recommended schedule in Table 11.3 of NFPA 96 / 2004 edition.

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