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HomeMy WebLinkAboutBuilding Correspondence 1990-10-11 ~ , ;./ . " Health 2>L{O'S 6a+~tJo..~ . ~ McDonald's Corporation McDonald's Plaza Oak Brook, Illinois 60521 McDonald's October 11, 1990 Direct Dial Numllm Mr. Gerald Davis Lane County Environmental 125 E. 8th Eugene, OR 97401 (708)-860-6800 Ext,-228 Fax:(708)-860-1442 SUbject: McDonald's Portable Hotcake Operation at Springfield, Or, Dear Mr. Davis, I thank you for the opportunity to discuss the referenced situation with you on the phone this morning. As promised, I have enclosed a book on two of the hotcake hotplates, and a copy of the operations procedure from our handbook for preparing and cooking the hotcakes. In view of your request that we exhaust this operation to the outside with a hood, I wish to appeal that such is neither necessary nor required by any code of which I am aware, though it does require a subjective understanding and interpretation, I am very familiar with ICBO, BOCA, SBCCI, many other State and Municipal codes, and NFPA-96 (of which I am a member). All of these address cooking exhaust requirements on the basis of the cooking operation producing some level of grease, smoke, or other effluent that is "excessive", "comparable", "appreciative", "laden", and so on. While none of these words state a definitive quantity, i~ is clear that they all understand that some threshold quantity of effluent must be present from the operation in order to require a hood. It is regrettable that a definitive threshold level has not been given as a protocol for such is not yet available, though one is in the works. , The reason for some threshold quantity of effluent being present to require a hood, is that the codes are written on the basis of being necessary to protect the public welfare, without being unduly restrictive or arbitrary. The public welfare could be harmed in cooking operations if the effluent from the cooking operations rose to such a concentration in a given area that it would be hazardous for the employees or the customers, or if grease accumulated to such a concentration that it posed a fire hazard. Thus cooking operations are potentially first a health hazard, and secondly a fire hazard. Where cooking, or other heated food operations are performed, there are many instances of low levels of effluent that clearly do not pose a health or fire hazard, and for these a hood is not commonly required, Such might be soup kettles, roller grills, popcorn poppers, small baking ovens, steam tables and bun steamers, and holding cabinets, to name a few, Similarly, there are toasters, coffee makers, cheese melters, and waffle irons that are not typically exhausted, but yet some of these could be set hot enough to ~ .~ ~ . . Mr. Davis McDonald's Hotplate Page 2 cook some meat product on'them and actually create an effluent hazard. Since such misuse is not anticipated, a hood is not required, Thus these examples serve to demonstrate that it is not the equipment alone that determines that an exhaust hood is required, but it is rather the total cooking operation which is a combination of the equipment, the product, and the temperature and method of operation that produces the effluent, and that is to be evaluated. It is therefore also, not what might be cooked on a piece of equipment, but what is cooked on the equipment that is to be evaluated. It is patently clear that if equipment is misused, it is to be judged on the basis of that misuse. What light effluent, water vapors, and heat come off of some of these appliances becomes part of the loading that must be considered in designing the heating, air conditioning, and ventilation within the kitchen area. At McDonald's, though the amount of exhausted equipment and the size of the kitchens may vary somewhat, all of the kitchens have a full exchange of the kitchen volume of air within 1-1/2 to 3 minutes, which is well above any ventilation requirement for a kitchen area. Thus these lesser vapors and heat loads are accounted for within our ventilation design. It should be noted also that McDonald's has long had QSC&V as it's motto, meaning Quality, Service, Cleanliness, and Value. We take this very seriously, including the "CO for Cleanliness. It is part. of my responsibility to be sure our stores do not become "greasy spoons" by having operations that would permit grease vapors to enter the kitchen space and deposit on the ceilings and walls. If this were a possibility with the hotcake hotplate, it would have a hood. At McDonald's, the hotcakes are normally cooked on one of the grills under a standard exhaust hood, and this issue does not then come into question. But when the volume and mix of breakfast product exceeds the ability of the existing hooded equipment, then it is necessary that ~e consider alternate methods, For this purpose we have developed portable cooking equipment for four of the breakfast items, namely, hotcakes, Egg McMuffins, and scrambled eggs, and biscuits. All of these have been designed in such a way that we feel none of them require a hood, Which piece or pieces are used at a partiCUlar store is dependent on the product mix and space requirements, The portable breakfast equipment is set up to operate only during the breakfast hours, The operation for it is specified to only cook the specific product for which it is intended. Once the breakfast periOd is finished, the equipment is rolled out of the way, cleaned, and stored for the next use, In most store layouts, it is mandatory that the equipment be moved, as the space it occupied is sUbsequently required for other support equipment that is used for the sandwich menu for the rest of the day, To hood the breakfast equipment, would be to void the flexibility of space usage that is required. The hotplate used for the hotcakes is cleaned after use, and a light film of shortening is put on it to prevent rusting, and to season it. , \.. ./. . . Mr, Davis McDona 1 d's Hotp 1 ate Page 3 When it is again used the next morning it is heated and wiped clean. No shortening is applied to the surface during any of the hotcake cooking. To do so would actually cause the hotcakes to stick to the plate. Thus the only real effluent from the hotcake operation is water vapor, and even that is difficult to see, What little shortening is in the batter mostly remains in the finished product for flavor. The enclosed operations section shows the batter preparation and the cooking of the hotcakes, This operational procedure is written without differentiating between a standard grill under a hood, and the portable hotcake hotplate. In the Note following Step 11, on Page 152, you will notice it cautions against cooking the hotcakes and the sausage on the same part of the grill as the hotcakes will stick, In the portable hotplate operation this is not a concern as all the sausage is cooked on a hooded grill, and only the hotcakes are cooked on the portable hotplate. It should be pointed out also, that in the nine or ten years that we have been using this portable hotplate throughout the U.S., we have never been required to exhaust it, Nor, for that matter, have we been required to exhaust any of these portable breakfast COOking operations, It has come into question in some juriSdictions, but has always been accepted without exhaust after it has been explained and demonstrated and/or appealed. We hope too that your office will give due consideration to the claims in this appeal and reconsider your original request for a hood over this operation, I look forward to hearing your response in this matter. If you or others desire, we will be pleased to arrange a demonstration of this operation at your convenience, We are also willing to provide whatever additional supporting materials you may desire for this evaluation, Please advise how we should proceed. You may phone or FAX the lab, where I am most often located, at the numbers at the top of this, letter. Patty Sanders, at our Portland office, (505)-684-9334 can also supply more information. You may write to me or Patty at one of the fOllowing addresses. McDonald's Air Research Lab 955 N. Lively Blvd. Wood Dale, Ill, -60191 500 S.W. Meadows Rd. Suite 200 Lake Oswego, OR -97034 Sincerely, , '-? / /'~/~ 7/" / Joseph N. Knapp ~ Staff Director/Engineering Encl: CC:' Patty Sanders/Portland Bob Desilets -110 , File: Appeal/Hotcake/Oregon