A practical guide for municipalities developing enforceable, sustainable FOG management programs.
Every successful Fats, Oils, and Grease (FOG) management program begins with more than good intentions—it begins with a well-written ordinance.
While grease interceptors, inspections, and education are all important components of a municipal FOG program, none of them are sustainable without the legal authority to require compliance. An effective ordinance establishes clear expectations for food service establishments, provides municipalities with consistent enforcement authority, and creates a framework that protects wastewater infrastructure for years to come.
Unfortunately, many communities inherit outdated sewer use ordinances or adopt language that addresses grease management only in broad terms. The result is often inconsistent enforcement, uncertainty for businesses, and increased maintenance costs due to recurring sewer blockages.
Whether your municipality is developing its first ordinance or updating an existing one, there are several essential components every successful FOG ordinance should contain.
Why Ordinances Matter
Municipal wastewater systems were never designed to transport large quantities of fats, oils, and grease. As grease cools within collection systems, it adheres to pipe walls, traps debris, and gradually restricts flow. Over time these accumulations contribute to sanitary sewer overflows (SSOs), emergency maintenance, environmental violations, and costly infrastructure repairs.
A comprehensive FOG ordinance provides municipalities with the authority to:
- Prevent grease from entering the sewer system
- Establish minimum equipment standards
- Require routine maintenance
- Conduct inspections
- Enforce compliance fairly and consistently
- Recover costs associated with violations
More importantly, it creates predictable expectations for businesses operating within the community.
1. Clearly Define Who Must Comply
Every ordinance should begin by clearly defining which facilities are considered Food Service Establishments (FSEs).
Typical facilities include:
- Restaurants
- Fast food establishments
- Hotels
- Schools and universities
- Hospitals
- Nursing homes
- Grocery stores
- Commercial kitchens
- Caterers
- Food manufacturers
- Churches and institutional kitchens
Clear definitions eliminate confusion and reduce disputes over applicability.
2. Establish Grease Interceptor Requirements
One of the most important ordinance components is establishing when grease interceptors are required.
The ordinance should address:
- New construction
- Remodels
- Change of ownership
- Change in menu or food preparation
- Existing facilities creating grease-related problems
It should also reference accepted engineering standards for sizing and installation while allowing the municipality flexibility to approve equivalent technologies where appropriate.
Rather than specifying a single manufacturer’s equipment, ordinances should establish performance requirements.
3. Require Permitting
Successful programs treat grease management much like any other utility permitting process.
Permit requirements often include:
- Initial registration
- Facility information
- Plumbing diagrams (when required)
- Interceptor specifications
- Maintenance provider information
- Emergency contact information
Permits also establish an up-to-date inventory of regulated facilities, making inspections and compliance tracking significantly easier.
4. Define Maintenance Standards
Installing a grease interceptor is only the beginning.
Without routine maintenance, even properly sized interceptors eventually fail.
An ordinance should establish:
- Cleaning frequency
- Maximum grease accumulation levels
- Proper disposal methods
- Record retention requirements
- Employee responsibilities
Many municipalities reference the “25 Percent Rule,” requiring interceptors to be cleaned before the combined grease and solids occupy more than 25% of the interceptor’s operating volume. This performance-based standard helps maintain interceptor effectiveness while allowing maintenance schedules to reflect actual usage.
5. Establish Inspection Authority
Municipal personnel need clear legal authority to verify compliance.
Inspection provisions should allow authorized representatives to:
- Inspect grease interceptors
- Review maintenance records
- Collect samples when necessary
- Verify operational condition
- Document violations
Routine inspections also provide valuable educational opportunities that often prevent enforcement actions.
6. Require Recordkeeping
Documentation protects both municipalities and businesses.
Most ordinances require facilities to maintain:
- Pumping manifests
- Service reports
- Maintenance logs
- Repair documentation
- Inspection reports
Many municipalities require records to be retained for a minimum of three years.
Digital recordkeeping is becoming increasingly common, simplifying compliance for both regulators and businesses.
7. Define Enforcement Procedures
One of the greatest weaknesses in many ordinances is vague enforcement language.
An effective ordinance should clearly identify:
- Notice of violation procedures
- Corrective action timelines
- Administrative penalties
- Cost recovery provisions
- Repeat offender escalation
- Permit suspension or revocation
- Emergency enforcement authority
Consistency is critical.
Businesses should understand exactly what happens when violations occur, while inspectors should have clear guidance for applying enforcement fairly across all regulated facilities.
8. Include Best Management Practices (BMPs)
Equipment alone cannot solve grease problems.
Employee practices often determine whether grease reaches the interceptor in the first place.
Many municipalities require documented Best Management Practices such as:
- Dry wiping cookware before washing
- Proper oil recycling
- Scraping food waste into trash containers
- Employee training
- Spill response procedures
- Proper chemical use around grease interceptors
BMPs reduce grease loading while extending interceptor life and lowering maintenance costs.
9. Address Variances and Appeals
No ordinance can anticipate every operational scenario.
Providing a structured variance and appeals process allows municipalities to evaluate unique circumstances while maintaining program integrity.
Clearly defined procedures increase transparency and reduce unnecessary disputes.
10. Keep the Ordinance Flexible
Technology continues to evolve.
Biological treatment systems, automated grease recovery devices, remote monitoring, and digital compliance platforms are becoming more common throughout the industry.
Rather than referencing specific technologies, ordinances should focus on measurable performance outcomes and allow municipalities to approve equivalent solutions as innovation advances.
Strongly consider as part of your local ordinance, a “catch your commercial kitchens doing something right” campaign where any commercial kitchen that does anything to help improve their ability to lower the amount of F.O.G. that they produce, or improve their systems to help ensure their F.O.G. does not end up at the water treatment plant, they should be made local heroes of their community!
Common Mistakes Municipalities Should Avoid
Some of the most common ordinance deficiencies include:
- Undefined inspection authority
- No maintenance frequency requirements
- Lack of recordkeeping requirements
- No enforcement escalation process
- Inconsistent definitions
- Outdated equipment specifications
- Limited authority for cost recovery
- No permitting process
Correcting these issues significantly improves long-term program effectiveness.
Ordinances Are More Than Enforcement Tools
The best FOG ordinances are not written to generate citations.
They are written to create consistency.
A well-designed ordinance gives businesses clear expectations, provides inspectors with consistent guidance, and equips municipalities with the authority necessary to protect public infrastructure. When paired with education, technical assistance, and ongoing communication, the ordinance becomes the foundation of a collaborative program that benefits everyone involved.
Looking Ahead
Creating an ordinance is only one step in building a successful municipal FOG program. Equally important is developing inspection protocols, educating food service establishments, establishing data management systems, and measuring program performance over time.
Future articles in this series will explore inspection best practices, grease interceptor maintenance, compliance strategies, and how municipalities can use data to continually improve program effectiveness.
References
- U.S. Environmental Protection Agency (EPA). Guide for Grease Management Programs.
- EPA Pretreatment Program guidance and Sanitary Sewer Overflow (SSO) resources.
- Byron Ross, FOG Policy Development presentation (Monitoring & Management Services).
- FOGBMP industry guidance and Best Management Practice resources.
- Representative municipal FOG ordinances and sewer use regulations from established U.S. wastewater utilities.