Hi Scott & Saskia,
It is clear that 188.8.131.52.(1) applies to this building, since the commercial cooking appliances fit the definition of an appliance in the FC.
184.108.40.206. (1) If a fuel-burning appliance or a fireplace is installed in a suite of residential occupancy, a carbon monoxide alarm shall be installed adjacent to each sleeping area in the suite.
I would proceed as Scott suggests, but by Inspection Order only citing the hazard of CO, but not by considering the cooking appliances as a building service. I do not think that route would survive an appeal or a challenge in court. Doing an Inspection Order based on the hazards of CO would allow you to appeal if it didn’t survive the FM review.
Building new, you would run into the same issue. On the same token many of the vulnerable occupancies are excluded from CO requirements. I have multi-unit residential buildings where HVAC systems heat the corridors, but the appliance is located on the roof. Those are very clearly exempted from the CO requirements.
It is kind of like the regulations related to two ways out. We promote the idea as a universal in our messaging, but the regulations are filled with exceptions.