National Resource Reference Guide

FOG discharged to the sewer can accumulate along sewer pipe walls coating pipes until wastewater flow through the line is restricted, causing SSOs and blockages. These occurrences may result in property damage, environmental problems in nearby surface waters, and public health hazards. There has been an increased emphasis on preventing SSOs recently, in part because of the pending United States Environmental Protection Agency (U.S.EPA) regulations for sanitary sewers, but also because new collection system requirements are being issued by state and local regulatory authorities. As a result, source control and pretreatment programs have had to reevaluate or establish FOG Control Programs, which may include a food service establishment (FSE) program component.

 

The six steps necessary to implement a FOG Abatement program are outlined below. This website contains references and documents created by Western States Alliance, the Pacific Northwest Pollution Prevention Resource Center (PPRC), and IW consulting Service, LLC. The USDA Rural Utilities Service provided funding for this resource.

Implementing a FOG Abatement Program

Follow the six steps below to create and implement a FOG Abatement Program.  Two excellent places to start are the WSA FOG Primer and the WSA FOG Source Control Guide.

Step 1:

Characterizing FOG Sources. Determine the cause of FOG blockages and the upstream sources of the FOG. Identify major sources of FOG to result in a more effective utilization of municipal resources when developing a FOG Abatement Program

 The worksheet, Characterizing FOG Sources Worksheet, will help systematically identify and characterize the amount of FOG produced by FSEs.

WSA’s FOG Source Control Guide contains the information to provide a thorough understanding of how FOG is discharged from commercial Food Service Establishments (FSEs), how kitchen fixtures are impacted by FOG and the most effective means of capturing FOG. It also contains kitchen best management practices (BMPs) to help reduce food waste and prevent FOG from entering the conveyance system.  See this video, a how-to guide to executing a FOG Triage Program.

WSA’s Grease Interceptor Product Standards (2019 Editions) is a thorough review that explains product standards which ensure that approved devices operate in accordance with minimum performance or design requirements.  It includes information on the standards that govern grease interceptors (plumbing standards and sizing methods) and testing and rating of grease interceptors.  

Step 2:

Understanding Regulatory Requirements. Researching and understanding regulatory requirements and legal framework are necessary for successful and enforceable FOG Abatement Program. 

The fact sheet, FOG Program Enforcement Options, also available in Spanish, provides examples of enforcement that can be accomplished within existing municipal code or as part of a newly created FOG Abatement Program. EPA’s enforcement response guidance, written in 1989, Guidance for Developing Control Authority Enforcement Response Plans is still valid and is a thorough and complete treatment of this subject.  

The FOG Rules Template can be used to help create rules for a municipality. EPA created an example ordinance, EPA R8 Example Ordinance, that can be used for municipalities without approved pretreatment programs. The Plumbing and Drainage Institute created a Model Grease Ordinance that can be used to update or establish a grease ordinance.

  

Step 3:

Establishing Program Administration. There are overlapping jurisdictions within a municipality with an in interest and authority over Food Service Establishments (FSEs). Creating a FOG Abatement Program takes coordination and communication with many stakeholders. The FOG Abatement Program – Establishing Program Administration worksheet is useful to clarify motivations and outcomes for the program.  

The fact sheet, Establishing an Ordinance to Control Fats Oils and Greases is effective to communicate with stakeholders about the need for a FOG Abatement Program and basic program components.  View the fact sheet in English or Spanish

Step 4:

Developing the FOG Abatement Program. The overall program development includes selection of the approach for regulating facilities (e.g., permits, incentives, or education), establishing FOG handling and disposal practices, developing a database, and establishing an operating budget. 

The FOG Abatement program – Establishing the Business Case Worksheet helps identify all the costs currently being incurred by the municipality – the cost of doing nothing, plus it contains considerations for ongoing program, stakeholder engagement, and implementation costs.

Incorporating a Preferred Pumper Program (PPP) into your FOG Abatement program can save you and your FSEs time and money. This 4-minute video explains what a preferred pumper program is and the reasons to have one.

 

This 20-minute video provides more detail on why you need a 3P, standards to follow, how to collaborate with pumpers and other stakeholders, benefits of a 3P, legal authority, and challenges and opportunities. 

Subscribe to our newsletter at the bottom of this page to receive news on case studies and details of key metrics and outcomes of FOG Abatement Program implementation across the United States. 

Step 5:

Providing Outreach. The FSEs and the public must be educated about why and how to prevent FOG from entering the sewer conveyance system. Activities may include arranging stakeholder meetings, providing best management practice (BMP) information, and providing educational materials. 

The fact sheet, Fats, Oils, and Grease Yellow vs Brown Grease can be used to educate FSEs about management tips and the value of both types of grease. 

Step 6:

Inspecting Food Service Establishments. Inspection methods must be developed to ensure compliance with regulatory requirements and to establish proper FOG handling and disposal procedures. 

Elements needed to conduct an FSE inspection are included in the FSE Inspection Checklist and the FOG Inspection Template

Being present periodically during a pump-out provides opportunity to view the condition of the interceptor both before and after cleaning.   See videos of this process  as well as guidance checklists.

Federal and State Legislative Information

Most states adopt plumbing codes, which are typically updated every three years, a few years after the codes are updated. Western States Alliance provides summaries of the Model Plumbing Codes.  See the 2015 or the 2018 edition of the Model Plumbing Codes summary.  

Financing

There are multiple sources of financing available for wastewater treatment plants, infrastructure, and education of stakeholders. The USDA Water and Environmental Programs have many special programs including grants, technical assistance, and loans.

  

The EPA provides a clearinghouse of funding and technical resources of interest from many sources, including individual state sources. The EPA Clearinghouse for Environmental Finance allows a user to choose Water, Land, or Air finance. There is a map, so you can see what is available in your state. There are “quick searches” so you can look for state revolving funds, case studies, small systems, wastewater treatment technologies, stormwater, webinars, environmental justice, or community revitalization.

Key Contacts

The US EPA maintains a list of state pretreatment coordinators and WSA also has a list of key wastewater authorities in the states that is continuously updated.