COMPLIANCE & REGULATIONS · SHARED KITCHEN VERTICAL
A converted warehouse off I-35 in Dallas holds fourteen kitchen stalls. Nine are delivery-only brands, two are caterers, one is a meal-prep company, one is a food truck operator’s commissary, and one turned over last month. They share a roof, a duct trunk, a fire marshal, and a certificate of occupancy — and not one of them knows when the exhaust system was last cleaned to bare metal, because every one of them assumes the facility handles it.
November 10, 2026 · By Facilitec Southwest
QUICK ANSWER
Ghost kitchens, commissary kitchens, and shared-use kitchens are commercial cooking operations under NFPA 96 like any restaurant — but the standard is applied to the exhaust system, not to the operator, and in a shared facility one system serves many operators. That has three consequences. First, the Table 12.4 inspection cadence is set by the aggregate cooking volume on the system, not by any single tenant’s: ten moderate-volume stalls on one duct trunk is a high-volume system, often on a monthly cadence, and 24-hour delivery operations push it further. Second, code responsibility sits with the facility operator, who holds the certificate of occupancy and is the party the fire marshal cites — the stall licenses assign cost but don’t move the citation. Third, the documentation has to exist at the system level (one written report, one service label per hood, one survey of the shared duct and fan) and be available to every tenant, because each tenant’s health permit, insurance, and delivery-platform agreements may require evidence of it. Facility operators in TX, OK, LA, NM, and AR should contract one certified vendor for the whole building, set the cadence at the aggregate, and deliver the report to every stall.
SHARED KITCHEN FACILITIES
Facilitec Southwest services ghost kitchen and commissary facilities across the Southwest — every stall hood, the shared duct trunk, and the roof, on one aggregate-volume schedule with a report delivered to the facility and every tenant.
See Our Institutional Kitchen Service →
1. What a Shared Kitchen Facility Actually Is
“Ghost kitchen” covers several different buildings that look similar from the outside and behave differently under NFPA 96.
| FACILITY TYPE | WHO COOKS THERE | EXHAUST CONFIGURATION | COMPLIANCE COMPLICATION |
|---|---|---|---|
| Ghost kitchen / delivery-only facility | Multiple delivery brands in individual stalls, often 8–30; some are virtual brands of established restaurants, some are startups | One hood per stall; stalls tied into a shared duct trunk or several trunks; shared roof fans | High stall turnover; aggregate volume far above any single tenant; 16–24 hour operation |
| Commissary kitchen | Food trucks, caterers, farmers-market vendors, cottage-food producers scaling up; licensed by the health department as the base of operations for mobile units | Often a single large production kitchen with one or two hoods used by many operators on a schedule | Many operators, one hood; volume depends on who’s booked; nobody “owns” the hood |
| Shared-use / incubator kitchen | Small food businesses renting by the hour or shift; nonprofit or municipal programs common | One to a few hoods, scheduled use | Operators are new to commercial cooking and unfamiliar with NFPA 96; the facility carries all compliance knowledge |
| Restaurant-hosted virtual brands | A single restaurant running several delivery brands from its own kitchen | The restaurant’s existing system | Not a shared facility — but the volume increase from added brands can change the Table 12.4 category |
| Food hall | Multiple independent concepts in a shared dining space, each with its own stall | Individual stall hoods, usually tied to shared trunks and fans | Same structure as a ghost kitchen, with a public assembly occupancy on top |
The first three are the subject of this post. Each has a facility operator — the company or organization that leases the building, builds out the stalls, holds the certificate of occupancy, and licenses space to the cooking tenants — and that facility operator is the party NFPA 96 and the fire marshal are ultimately looking at.
2. The Aggregate-Volume Problem
NFPA 96 Table 12.4 sets inspection frequency by the type and volume of cooking. For a standalone restaurant, that’s straightforward: the kitchen cooks a certain way at a certain volume, and the category follows. For a shared facility, the question is harder, because the thing being inspected — the exhaust system — serves many kitchens.
The system is the unit, not the stall
Section 12.6.1.1 requires inspection of the hood, grease removal devices, fans, ducts, and other appurtenances for grease buildup. In a ghost kitchen, ten stall hoods tie into a shared horizontal duct trunk that runs the length of the building to one or two roof fans. The trunk and the fans receive the combined grease output of every stall on the run. A trunk that carries the exhaust of ten moderate-volume stalls is, for Table 12.4 purposes, a high-volume system — regardless of how any individual stall would be classified on its own.
| SCENARIO | PER-STALL CATEGORY | SYSTEM CATEGORY | PRACTICAL CADENCE |
|---|---|---|---|
| 12 delivery stalls, griddle/fryer, 16 hrs/day, shared trunk | Moderate | High-volume | Quarterly minimum; monthly for the trunk and fans is common |
| Same, with 3 stalls charbroiling or wok cooking | Mixed | High-volume with monthly-category contributors | Monthly inspection of the trunk and fans; monthly for the charbroil/wok stalls; quarterly for the rest |
| Commissary, one hood, 20 food trucks on a prep schedule | N/A — one hood | Depends on scheduled hours; usually moderate to high | Quarterly; monthly if 24-hour booking |
| Incubator kitchen, two hoods, light baking and prep, 40 hrs/wk | Low to moderate | Moderate | Semiannual to quarterly |
| 24-hour delivery facility, any size | Any | 24-hour cooking operation per Table 12.4 | Monthly |
Our post on how often to clean a commercial kitchen exhaust system covers Table 12.4 in detail. The shared-facility rule is simpler: set the cadence by the busiest category on the trunk and by the aggregate hours of operation, and inspect the trunk and fans at least as often as the busiest stall.
FIELD NOTE — THE QUARTERLY FACILITY WITH A MONTHLY TRUNK
A ghost kitchen facility in the Houston market had every stall on a quarterly contract — reasonable for the stalls individually. The shared trunk ran above a drop ceiling the length of the building and nobody had thought about it as a separate thing. Eleven stalls, two of them wok concepts, feeding one 40-foot horizontal run to a pair of roof fans. When we opened the trunk’s access panels at the first service, the grease depth in the horizontal run was past threshold six weeks after the previous vendor’s “quarterly cleaning” — because the previous vendor had cleaned eleven hoods and eleven short vertical risers, and had never opened the trunk. The stalls were fine. The system wasn’t.
3. Who Is Responsible
Shared facilities have the same code-versus-contract split our post on landlord and tenant responsibility describes for leased restaurants — compressed into one building with ten or twenty tenants instead of one.
Code responsibility: the facility operator
The facility operator holds the certificate of occupancy, holds the relationship with the fire marshal, and owns or leases the exhaust system. When the fire marshal finds a grease-loaded trunk, the citation goes to the facility, not to stall number seven. Delivery brands come and go; the building and its exhaust system stay. The facility operator cannot assign this to the tenants.
Contractual responsibility: whatever the license says
Stall licenses and commissary agreements assign cost, and most do so in one of two ways: a facility-wide service contracted by the operator and billed into the stall fee, or a per-stall obligation on each tenant. The first works. The second produces the quarterly-facility-with-a-monthly-trunk problem — ten tenants hire ten vendors on ten schedules, each cleans their own hood and riser, and the shared trunk and fans belong to no one.
| PARTY | HOLDS | SHOULD DO |
|---|---|---|
| Facility operator | Certificate of occupancy; the exhaust system; the fire marshal relationship; the lease with the building owner | Contract one certified vendor for every hood, the trunk, the fans, and the roof; set cadence at the aggregate; deliver the report to every tenant; hold the file |
| Stall tenant / delivery brand | Health permit for the stall; delivery-platform agreements; their own insurance | Get a copy of every report; keep it with the health permit; confirm the stall hood is on the facility’s survey; maintain filters daily — this is the tenant’s job under NFPA 96, not the vendor’s |
| Commissary user (food truck, caterer) | Mobile unit permit that lists the commissary as base of operations | Confirm the commissary’s exhaust documentation is current — the truck’s own Chapter 17 compliance is separate (see our food truck post) |
| Building owner / landlord | The roof; the master lease | Require the facility operator to maintain the system per NFPA 96, deliver reports, and install rooftop containment; see our containment post |
| Fire marshal | Enforcement under the adopted fire code | Inspects the facility as one occupancy; asks the facility operator for the file |
THE ONE-VENDOR RULE
A shared exhaust system needs one vendor, one schedule, one survey, and one report — contracted by the party that holds the certificate of occupancy. Ten tenants with ten vendors is ten partial cleanings and one uncleaned trunk.
4. The Survey a Shared Facility Needs
Every shared facility should have a hood survey that goes beyond the standard list of hoods. The shared infrastructure is what makes these buildings different, and it’s what the survey has to capture.
- Every stall hood, by stall number, with the tenant currently in it, the appliances under it, the Type 1 or Type 2 classification (see our Type 1 vs. Type 2 post), and the Table 12.4 category for that stall’s cooking.
- Every riser from each hood to the trunk, with its access panel location.
- The trunk(s) — route, length, every access panel per Section 12.6.4 and 12.6.10, every junction where a riser enters, and the slope and drain points where grease collects. A 40-foot horizontal trunk needs access panels at intervals the standard specifies; many ghost kitchen build-outs don’t have them. Our post on the access panel rule explains the requirement.
- Every fan — which stalls feed it, hinge kit per Section 8.1.1.1, containment per Section 7.8.2.1, roof condition around it.
- Suppression coverage — each stall hood has its own system; the tags, the contractor, and the semiannual dates, per Chapter 11. Shared facilities frequently have stalls whose suppression was never re-tagged after a tenant change.
- The aggregate cadence — the category the trunk and fans are on, with the reasoning written down, so the fire marshal and the tenants can see why.
- Vacant stalls — a hood with no tenant still ties into the trunk and still has a suppression system; it belongs on the survey with a note.
The survey is updated at every tenant change. A stall that turns from a salad concept to a fried-chicken brand changes its own category and the trunk’s aggregate; the facility operator has to know.
5. Turnover, Vacancy, and the Stall Nobody Cleaned
Ghost kitchen stalls turn over fast — delivery brands test a market and leave, startups run out of runway, successful brands graduate to their own space. A facility with twenty stalls might see six or eight tenant changes a year. Each one is an exhaust event.
- The outgoing tenant’s grease stays. Unless the license requires a bare-metal cleaning at surrender, the next tenant inherits whatever is in the hood and riser — and the trunk has absorbed it already.
- The incoming tenant’s category may differ. A wok concept replacing a sandwich concept moves the stall to monthly and raises the trunk’s aggregate.
- Suppression isn’t automatically re-verified. New appliances under the hood may not match the nozzle layout the suppression system was designed for. That’s a licensed suppression contractor’s call — see our suppression post — but the facility should trigger it.
- Vacant stalls drift off the schedule. A hood with no tenant gets skipped at the next service because “nobody’s cooking there.” Its riser still connects to the trunk; its filters, if left in, still hold grease; its suppression tag still expires.
The facility operator’s license should require the outgoing tenant to leave the stall hood cleaned to bare metal per Section 12.6.5 with a report, and the facility should re-survey the stall before the incoming tenant’s first service. Our post on opening a new restaurant covers the pre-opening picture that applies to each new stall.
FIELD NOTE — STALL NINE
A delivery facility in the DFW market had a stall that had been vacant for five months. The previous tenant was a Nashville hot chicken brand — fryers running sixteen hours a day. They left without a surrender cleaning. The facility’s vendor skipped the stall at the next two quarterly services because it was empty. When a new tenant moved in and the facility asked us to survey, the stall hood plenum had a quarter-inch of hardened fryer grease, the riser was loaded to the trunk junction, and the suppression tag had expired three months earlier. The new tenant — a meal-prep company doing light sauté — would have started cooking under a system that was already past threshold on day one.
6. Documentation for a Building Full of Tenants
A standalone restaurant’s exhaust documentation gets read by the fire marshal, the insurer, and maybe the landlord. A shared facility’s gets read by all of those plus every tenant’s health inspector, every tenant’s insurer, and — increasingly — delivery platforms and brand licensors that audit the facilities their partners cook in.
| DOCUMENT | LEVEL | WHO NEEDS IT |
|---|---|---|
| Facility hood survey (stalls, risers, trunk, fans, suppression, aggregate cadence) | Facility | Facility operator, fire marshal, building owner, facility’s insurer |
| Service label per Section 12.6.13 | Every stall hood | Fire marshal walks stall by stall; each tenant’s health inspector sees the hood |
| Written report per Section 12.6.15 | System-wide, with a per-stall section | Facility file; copy to every tenant for their health permit and insurance |
| Trunk and fan inspection record | Facility | The document that proves the shared infrastructure is on a cadence — the one most facilities don’t have |
| Suppression tags and reports per Chapter 11 | Every stall | Facility and tenant; re-verified at tenant change |
| Surrender cleaning reports | Per stall turnover | Facility; incoming tenant |
| Rooftop containment service record | Facility | Building owner; stormwater compliance — see our wastewater post |
The multi-location structure from our post on multi-location kitchen compliance applies here with one change: the “locations” are stalls in one building, and the shared trunk is a location of its own.
SIGNATURE APPROACH
From Cooktop to Rooftop means every stall hood, every riser, the full length of the shared trunk, and every fan — on one schedule set by the building’s aggregate volume, with one written report that has a page for the facility and a page for every tenant. Our Phil Ackland Certified Technicians survey the building at every tenant change and service vacant stalls with the occupied ones. The outcome is a Grease-Free and Fire-Safe facility, and the peace of mind that comes with it for the operator whose name is on the certificate of occupancy.
7. What Each Party Should Do This Month
If you operate a shared facility
- Get a full-building survey that includes the trunk, every access panel, and the fans — not just the stall hoods.
- Set the cadence at the aggregate and write down why.
- Move to one vendor for the whole building if you aren’t there already; bill it into the stall fee.
- Add surrender-cleaning and re-survey requirements to the stall license.
- Deliver every report to every tenant, and keep the master file.
If you cook in one
- Ask the facility for the most recent written report and the survey. If they can’t produce it, that’s the answer.
- Confirm your stall hood has a current service label and your suppression tag is within six months.
- Clean your filters daily — that’s yours, not the facility’s.
- Keep the facility’s report with your health permit; your insurer and your platform partners may ask.
- If you’re moving in, ask whether the stall was cleaned at the last tenant’s surrender. If it wasn’t, ask for it before you start.
Frequently Asked Questions
Does NFPA 96 apply to ghost kitchens?
Yes. A ghost kitchen, commissary, or shared-use kitchen is a commercial cooking operation producing grease-laden vapors, and every Type 1 hood in it falls under NFPA 96 inspection and cleaning requirements. The difference from a restaurant is structural: one exhaust system serves many operators, so Table 12.4 cadence is set by the aggregate volume on the shared duct and fans, and code responsibility sits with the facility operator who holds the certificate of occupancy.
Who is responsible for hood cleaning in a ghost kitchen — the facility or the tenant?
The facility operator holds code responsibility: they hold the certificate of occupancy, own or lease the exhaust system, and receive the fire marshal’s citation. The stall license assigns who pays. The workable structure is a facility-wide contract with one certified vendor, billed into the stall fee, with the written report delivered to every tenant. Per-stall vendor obligations leave the shared trunk and fans uncleaned.
How often does a shared exhaust system need to be inspected?
At the cadence for the aggregate cooking on the system, not any single stall. Ten moderate-volume stalls on one trunk is a high-volume system — quarterly at minimum, with monthly inspection of the trunk and fans common. Any charbroiling or wok stall puts its riser and the downstream trunk in the monthly category. A 24-hour delivery facility is a 24-hour cooking operation under Table 12.4 and is monthly regardless of size.
What is the shared duct trunk and why does it matter?
The horizontal duct that collects exhaust from multiple stall hoods and carries it to the roof fans. It receives the combined grease output of every stall on the run, it’s usually above a ceiling where nobody sees it, and it’s the part of the system most often skipped by vendors contracted stall-by-stall. It needs access panels at the intervals NFPA 96 specifies, its own line on the survey, and inspection at least as often as the busiest stall feeding it.
Do vacant stalls need to be cleaned?
Yes. A vacant stall’s hood still ties into the shared trunk, its filters (if left in place) still hold grease, and its suppression system still has a tag that expires. Stalls skipped during vacancy are a common finding at tenant turnover. The facility should service vacant stalls with the occupied ones and require a bare-metal surrender cleaning from the outgoing tenant.
I’m a delivery brand renting a stall. What should I ask the facility for?
The most recent written report per NFPA 96 Section 12.6.15 for the system, the facility hood survey showing your stall and the trunk, confirmation that your stall hood has a current service label per Section 12.6.13, and the suppression tag date for your hood. Keep the report with your health permit — your insurer and delivery-platform partners may ask for it. If the facility can’t produce the report, that tells you where the system stands.
Does a commissary kitchen for food trucks fall under NFPA 96?
Yes — the commissary’s hood and exhaust system are a commercial cooking operation under Chapters 1 through 16, with cadence set by the total scheduled cooking hours across all the operators who use it. The food trucks themselves are separately covered by Chapter 17, with their own hoods, suppression, and cleaning cadence. A truck operator needs both: the truck’s compliance and the commissary’s.
What happens to the exhaust system when a stall changes tenants?
Three things should happen: the outgoing tenant leaves the stall hood cleaned to bare metal per Section 12.6.5 with a report; the facility re-surveys the stall for the incoming tenant’s appliances and Table 12.4 category; and the suppression system is re-verified by a licensed contractor if the appliance layout changed. When none of these happen, the new tenant starts cooking under a system that may already be past threshold.
Does adding virtual delivery brands to my restaurant change my cleaning cadence?
It can. Running three delivery brands from one kitchen often means longer hours and more fryer and griddle time than the dine-in menu alone — enough to move a moderate-volume kitchen toward high-volume under Table 12.4. Tell your vendor when you add brands or extend hours so the cadence follows the actual volume.
Who does the fire marshal cite in a ghost kitchen?
The facility, as the holder of the certificate of occupancy for the building. The fire marshal inspects a shared facility as one occupancy and asks the facility operator for the documentation. Individual stall tenants may be cited for conditions inside their stall — blocked suppression nozzles, loaded filters — but the exhaust system citation goes to the facility.
How does Facilitec Southwest work with shared kitchen facilities?
Full-building survey including every stall, riser, the shared trunk with every access panel, the fans, and suppression tag dates; aggregate-volume cadence with the reasoning documented; one service contract for the whole building; vacant stalls serviced with occupied ones; re-survey at every tenant change; surrender cleanings with reports; and a written report with a facility page and a page for every tenant. Service across TX, OK, LA, NM, and AR. See our institutional kitchen service.
NFPA 96, 2024 Edition — Chapter 1 (scope); Section 12.6.1 (responsibility; qualified person); Section 12.6.1.1 (inspection of hoods, grease removal devices, fans, ducts, and appurtenances); Table 12.4 (inspection frequency by cooking type and volume, including 24-hour operations); Section 12.6.4 (accessibility); Section 12.6.5 (cleaning to bare metal); Section 12.6.10 (access panel marking); Section 12.6.13 (service label); Section 12.6.15 (written report); Chapter 7 (duct systems, including access panel intervals on horizontal runs); Section 8.1.1.1 (fan hinge kit); Section 7.8.2.1 (rooftop grease collection); Chapter 11 (fire-extinguishing system maintenance); Chapter 17 (mobile cooking, for commissary-based trucks). Application of Table 12.4 to a shared exhaust system by aggregate volume reflects the standard’s inspection of the system as a whole and common AHJ practice; the specific cadence for any facility is determined by the qualified inspector and the AHJ. Commissary licensing requirements for mobile food units are set by state and local health authorities and vary by jurisdiction. Facility-type descriptions are general; the category names “ghost kitchen,” “cloud kitchen,” “commissary,” and “shared-use kitchen” are used descriptively and do not refer to any specific company. Field Notes describe composite service situations with identifying details changed. Facilitec Southwest cleans kitchen exhaust systems and does not install, service, or verify fire suppression systems. Phil Ackland Certified Technicians follow NFPA 96 guidelines for cleaning and inspection of grease buildup. This article is a compliance reference, not legal or AHJ-specific advice.

