NFPA 96 Changes in 2024-2025: What Restaurant Owners Must Know

The 2024 edition of NFPA 96 tightened the focus on responsibility, inspection records, inaccessible areas, and full-system maintenance. In 2025, New York State’s updated Fire Code gave restaurants outside NYC a new enforceable state-code layer for commercial cooking systems, while still tying those systems to the broader NFPA 96 fire-protection framework. Connecticut operators still need to follow the NFPA 96 requirements adopted through their state code and enforced by the local fire marshal.

Given these updates, Connecticut and New York restaurant owners should check three things: which code edition the local fire official is applying, whether the cleaning schedule still matches the kitchen’s actual grease load, and whether the service report documents the hood, ducts, access panels, and rooftop fan. New York City operators also need to account for FDNY approval and local decal requirements.

This article breaks down what changed, what did not change, and what owners should verify before the next inspection, insurance review, or vendor visit.

What NFPA 96 Covers

Most owners think first about the metal canopy above the cooking line. NFPA 96 covers the entire exhaust path, including the parts hidden above the ceiling and on the roof.

System Component	Why It Matters
Hood canopy	Captures smoke, heat, and grease vapor above cooking equipment
Grease filters	Reduce grease entering the duct system
Plenum	Collects grease vapor behind the visible hood area
Ductwork	Carries grease-laden air through the building
Access panels	Allow inspection and cleaning inside duct runs
Rooftop exhaust fan	Pulls air through the system and collects grease at the fan housing
Rooftop grease containment	Keeps grease from collecting on the roof surface
Fire suppression system	Protects cooking appliances and ties into fuel shutoffs

This is why visible hood cleaning is not enough. A hood canopy can look clean while the duct run or rooftop fan still contains grease. If you need a broader refresher on the local code framework, read our CT and NY restaurant fire code guide that explains how NFPA 96 fits into local enforcement.

NFPA does not inspect restaurants. The standard becomes enforceable through state codes, local fire officials, insurance requirements, and lease terms.

What The 2024 NFPA 96 Edition Clarified

NFPA’s public revision records show targeted clarifications, not a complete rewrite of restaurant hood-cleaning rules. These are the items in the public record that matter most to a restaurant owner.

2024 Clarification Or Update	Practical Meaning For Owners
Owner responsibility	The revised language clarifies that the equipment owner is responsible for inspection, testing, maintenance, and cleanliness unless that duty is transferred in writing. It also clarifies that a periodic service contractor does not assume that responsibility.
Written reports after inspection or cleaning	Reports must specify areas that were inaccessible, not inspected, not cleaned, or in need of cleaning. The revision record also includes a two-week window for providing written reports to the owner or owner’s agent.
Labels after inspection or cleaning	The revision record calls for an adhesive label on the hood after an exhaust system is inspected or cleaned, tied to the service provider and person performing the work.
Mobile and temporary cooking	The revision record adds more direct attention to food trucks, pop-ups, and temporary cooking setups. Fixed restaurant operators are not the primary audience for this change.

The common thread is traceability. The 2024 updates put more weight on whether an owner can show who inspected the system, what they found, what they could not access, and what record was left behind.

A useful report does not stop at “cleaned.” It says what the technician opened, what was cleaned, what could not be reached, and what follow-up work is needed. That is the difference between a receipt and a defensible maintenance record.

What Did Not Change

Some summaries of the 2024-2025 NFPA 96 changes make the updates sound broader than they are.

For example, there is no verified new national 2025 rule requiring every restaurant to clean monthly. Cleaning frequency still depends on cooking volume, fuel type, grease load, and the local Authority Having Jurisdiction (AHJ). A high-volume charbroil kitchen and a low-volume church kitchen do not belong on the same schedule. More about the cleaning schedule is covered in Kitchen Guard’s NFPA 96 hood cleaning schedule.

Another example is digital reporting. There is no verified universal NFPA mandate for a specific reporting platform. Digital reports and before-and-after photos are strong proof, especially for insurance and landlord questions, but the useful question is simpler: can the restaurant produce a complete record when the fire marshal asks?

Paper records are not automatically invalid. A paper record that identifies the date, vendor, areas cleaned, inaccessible areas, and deficiencies is stronger than a vague digital invoice that says only “hood cleaning.”

Claims about UL 300 also need careful handling. UL 300 relates to fire testing for commercial cooking fire suppression systems, but owners should not treat “new 2025 UL 300 rule” claims as fact without local confirmation. Ask your fire suppression contractor when the system was last evaluated and whether it is currently accepted by the AHJ and insurer.

What CT And NY Owners Should Check

Start with this short audit before the next inspection, insurance review, or vendor visit.

Check	Question To Ask
Code edition	Which NFPA 96 edition or local fire code is the AHJ applying?
Cleaning frequency	Does the schedule match current cooking volume, menu, equipment, and grease load?
Menu changes	Has the restaurant added charbroiling, wok cooking, breakfast service, longer hours, or solid fuel?
Responsibility	If the space is leased, who holds maintenance responsibility in writing?
Access	Can the vendor reach the ductwork, access panels, and rooftop fan?
Documentation	Does the report show what was cleaned and what was inaccessible?
Tags	Are old tags removed or covered so the current service date is clear?
Suppression records	Are suppression service records separate from exhaust cleaning records?

Doing nothing can be the right answer if the system is already clean, accessible, and documented. The risk is assuming that a sticker proves the full system was cleaned.

Owners often worry that a full-system inspection will uncover repairs or added cleaning costs. The better move is to find those issues early, before an inspection deadline turns routine maintenance into an urgent correction.

Questions To Ask Your Hood Cleaning Vendor

Use these questions before the next service. They are practical due diligence, not a technical exam.

1. Which NFPA 96 edition and local code requirements are you applying to this kitchen?
2. Do you clean the full system, including ductwork, access panels, fan housing, fan blades, and rooftop components?
3. Do you provide before-and-after photos?
4. Do you document inaccessible areas and recommended repairs in writing?
5. Do you provide a written service report, and when is it delivered?
6. Can you provide the written scope before service, including how repair recommendations or added work are handled?
7. Do you remove or update old tags so the current service date is clear?|

Depending on location and equipment, also ask:

8. If this is in New York State, what cleaning standard does the local code or AHJ expect?
9. If this is in NYC, are the vendor and technician currently FDNY-approved for this work?
10. If this kitchen uses solid fuel, smokers, wood-fired equipment, or charcoal, what inspection and cleaning tier applies?

If the answer to most questions is “we leave a sticker,” that is not enough. For a fuller vendor-selection checklist, readChoosing a Restaurant Hood Cleaning Company in CT & NY.

What Inspectors, Insurers, And Landlords Want To See

Different reviewers ask for different proof.

Reviewer	What They Care About	What The Owner Should Have Ready
Fire marshal or AHJ	Full-system condition, access, tags, deficiencies	Report, photos, tag, inaccessible-area notes
Insurance carrier	Maintenance history and risk control	Multi-service records, reports, photos, repair follow-up
Landlord or property manager	Lease compliance and building risk	Current service record and next-service plan
Health inspector	Visible grease and sanitation risk	Clean visible areas plus proof of professional maintenance

A fire marshal can look beyond the hood surface. Filters, access panels, duct interiors, rooftop fan condition, old tags, and uncorrected deficiencies can all matter.

An insurer may ask for maintenance records during renewal or after a fire. A landlord may ask because the building’s own insurance policy requires proof that tenants are maintaining fire-risk systems. An invoice alone is weak evidence.

Health inspectors focus on visible sanitation conditions. Grease dripping from the hood, dirty filters, and poor ventilation can prompt fire marshal follow-up, turning one hood issue into two inspection problems.

Connecticut, New York State, And NYC Differences

Jurisdiction	What Owners Should Know
Connecticut	Connecticut’s 2022 fire prevention code materials state that operation, inspection, and maintenance of commercial cooking equipment must comply with Chapter 50 and NFPA 96.
New York State outside NYC	New York State’s 2025 Fire Code places commercial cooking equipment and systems in Section 606. The state code is the enforceable layer for restaurants outside NYC, while NFPA 96 remains part of the commercial cooking fire-protection framework. Inspection and cleaning records must identify who performed the work and when it occurred. Hood or duct inspections require a conspicuous tag with service provider name, address, phone, and service date. Prior tags must be covered or removed.
New York City	NYC restaurants face a stricter FDNY layer. The NYC Fire Code requires commercial cooking exhaust systems to be cleaned by an approved cleaning company. NYC owners should verify vendor approval, technician credentials, and decal or tag accuracy.

Connecticut operators should treat the local fire marshal as the controlling practical authority. One town may focus on documentation. Another may focus on access panels, visible grease, suppression records, or rooftop fan condition. That local variation makes complete records more valuable.

New York State’s 2025 code also gives owners a useful inspection-frequency reference:

Cooking Operation	Inspection Frequency
High-volume cooking, including 24-hour cooking, charbroiling, or wok cooking	3 months
Low-volume operations, including places of religious worship, seasonal businesses, and senior centers	12 months
Solid fuel-burning cooking appliances	1 month
All other cooking operations	6 months

For multi-location operators, the records should be standardized across sites. The state framework can be the same while the inspection emphasis changes by municipality.

Documentation Owners Should Keep After Every Cleaning

A sticker or invoice can show that a visit occurred. It does not prove the ductwork, fan, access panels, or inaccessible sections were handled correctly.

Record Item	What It Should Show	Why It Matters
Written service report	Date, vendor, technician, scope, findings	Proves more than a vendor visit
Before-and-after photos	Hood, plenum, ducts, access panels, fan, rooftop	Makes the work easier to verify
Tag, decal, or sticker	Current service date and vendor details	Gives inspectors a visible service marker
Inaccessible-area notes	What could not be reached and why	Prevents false confidence
Deficiency notes	Repairs, missing access, damaged parts	Creates a follow-up record
Invoice	Billing record tied to the service	Supports administrative proof
Next service recommendation	Timing based on grease load and operation type	Shows ongoing maintenance planning

Keep the full set on-site or readily accessible for the AHJ. Maintain digital copies as backup. Do not rely only on a vendor portal if no one at the restaurant can access the record during an inspection.

Confirm record-retention requirements with the local AHJ. Until you have a local answer, keep at least one to three years available, and keep longer if your lease or insurance policy requires it.

Common Mistakes That Create Inspection Risk

The biggest mistake is not always skipped cleaning. It is partial cleaning with poor documentation.

Common failures include:

• No ductwork photos
• No rooftop fan documentation
• No access panel notes
• No inaccessible-area disclosure
• No deficiency report
• Old tags left in place
• No current next-service plan
• Cleaning frequency not updated after menu, equipment, or operating-hour changes
• No written responsibility assignment for tenant-operated kitchens
• Suppression service records confused with exhaust cleaning records

Owners often avoid full-system questions because they fear surprise repairs. That can create a larger problem: paying for partial cleaning while hidden grease, access issues, or old deficiencies remain undocumented.

Filter condition belongs in the report as well. Damaged, warped, or grease-loaded filters can allow more grease to move into the ductwork and fan.

The 2024-2025 NFPA 96 Hood Cleaning Changes: In Summary

The 2024 NFPA 96 edition clarified three things that matter operationally. First, owner responsibility: the equipment owner is responsible for inspection, testing, maintenance, and cleanliness unless that duty is formally transferred in writing. Hiring a cleaning vendor does not transfer that responsibility. Second, written reports: service reports must now specify what was inaccessible, what was not cleaned, and what needs correction, not just confirm that a visit occurred. Third, labels: an adhesive label tied to the service provider must be placed on the hood after inspection or cleaning.

In 2025, New York State added a new enforceable layer through its updated Fire Code, placing commercial cooking systems under Section 606 with specific record-keeping requirements, a mandatory service tag, and a published frequency table tied to cooking volume and fuel type.

For Connecticut, the enforcement authority remains the local fire marshal operating under the state fire code framework that references NFPA 96. The practical effect is the same: a sticker is no longer a sufficient answer when a fire marshal, insurer, or landlord asks for proof of maintenance.

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