Office of Water 1 

EPA-833-F-12-003

September 2012

[This Fact Sheet replaces EPA-833-F-07-007, July 2007]

Summary The National Pretreatment Program implements Clean 

Water Act requirements to control pollutants that are 

introduced into POTWs. As part of this program, EPA 

has promulgated General Pretreatment Regulations that 

require the establishment of State and local 

pretreatment programs to control pollutants which pass 

through or interfere with POTW treatment processes or 

may contaminate POTW sewage sludge. Meeting these 

requirements may require elimination of interference 

caused by the discharge to POTWs of Fats, Oils, and 

Grease (FOG) from food service establishments (FSE). 

More specifically, the Pretreatment Program regulations 

at 40 CFR 403.5(b)(3) prohibit “solid or viscous 

pollutants in amounts which will cause obstruction” in 

the POTW and its collection system.

What is the 

environmental 

problem with FOG 

discharges into 

sewers?

EPA’s Report to Congress on combined sewer overflows 

(CSOs) and sanitary sewer overflows (SSOs) identified 

that “grease from restaurants, homes, and industrial 

sources are the most common cause (47%) of reported 

blockages. Grease is problematic because it solidifies, 

reduces conveyance capacity, and blocks flow.” See 

Impacts and Controls of CSOs and SSOs, EPA-833-R-04 

001, August 2004. 

Controlling FOG discharges will help POTWs prevent 

blockages that impact CSOs and SSOs, which cause 

public health and water quality problems. Controlling 

FOG discharges from FSEs is an essential element in 

controlling CSOs and SSOs and ensuring proper 

operations for many POTWs. The interference incidents 

identified in CSO/SSO Report to Congress may indicate 

the need for additional oversight and enforcement of 

existing regulations and controls. See 71 FR 76660 

(21 December 2006).

National Pretreatment 

Program 

(40 CFR 403)

Controlling Fats, Oils, and Grease 

Discharges from Food Service 

Establishments 
Office of Water 2 

EPA-833-F-12-003

September 2012

[This Fact Sheet replaces EPA-833-F-07-007, July 2007]

What is the 

source of FOG at 

Food Service 

Establishments? 

FOG wastes are generated at food service 

establishments (FSEs) as byproducts from food 

preparation activities. FOG captured on-site is generally 

classified into two broad categories: yellow grease and 

grease trap waste. Yellow grease is derived from used 

cooking oil and waste greases that are separated and 

collected at the point of use by the food service 

establishment.

The annual production of collected grease trap waste 

and uncollected grease entering sewage treatment 

plants can be significant and ranges from 800 to 17,000 

pounds/year per restaurant.

What is the legal 

authority for 

POTWs to require 

FSEs to control 

FOG discharges?

The National Pretreatment Program already provides 

the necessary regulatory tools and authority to local 

pretreatment programs for controlling interference 

problems. Under the provisions of Part 403.5(c)(1) & 

(2), a POTW must establish and enforce specific local 

limits for industrial users to prevent interference with

the operation of the municipally-owned treatment works

in the following circumstances: 

 (1) POTWs with approved pretreatment programs; 

 (2) POTWs that have experienced Interference or 

Pass-Through and such violation is likely to recur. 

See also 46 FR 9406 (28 January 1981). 

Consequently, pretreatment oversight programs should 

include activities designed to identify and control 

sources of potential interference and, in the event of 

actual interference, enforcement against the violator.

How do POTWs 

determine whether 

they have FOG 

issues and how to 

address them? 

POTWs should base their FOG programs on knowledge 

of their systems and a suite of best practices that have 

proven to reduce FOG discharges and related backups 

in their collection systems. These efforts are often best 

implemented through a Capacity, Management, 

Operations, and Maintenance (CMOM) or an Asset 

Management program which provides a framework for 

addressing FOG and other collection system challenges.

The use of Geographic Information System (GIS) 

mapping to inventory and locate entities that produce 

FOG constituents, paired with a complaint database that 

notes when FOG is responsible for blockages, can be a 

powerful tool in assessing problems and developing 

solutions. With knowledge of the sources and of 
 

 

 

 

 

 

 

 

 

How can CMOM 

help control FSE 

FOG discharges? 

problems areas, a number of steps can then be taken to 

ensure that FOG does not impact the smooth 

functioning of the system. A POTW may work towards 

amending or putting in place a FOG ordinance to be 

followed in the community, or establish design 

requirements for grease traps or other structures to 

prevent FOG from entering the collection system. 

POTWs should establish an enforcement program to 

ensure compliance with FOG related policies and 

ordinances, including an inspection program to ensure 

that related equipment is working properly. In addition, 

POTWs may target or prioritize cleaning of the 

distribution systems based on discharges due to FOG or 

other root causes. For examples of controls, local 

limits, and/or pollution prevention measures, see 

“Where can I get more information?” below). 

EPA expects that blockages from FOG discharges will 

decrease as POTWs incorporate FOG reduction activities 

into their Capacity, Management, Operations, and 

Maintenance (CMOM) program and daily practices. 

CMOM programs are comprehensive, dynamic, utility 

specific programs for better managing, operating and 

maintaining sanitary sewer collection systems, 

investigating capacity constrained areas of the 

collection system, and responding to SSOs. 

Collection system owners or operators who adopt FOG 

reduction activities as part of their CMOM program 

activities are likely to reduce the occurrence of sewer 

overflows and improve their operations and customer 

service. 

What can FSEs do 

to control FOG 

discharges? 

Food service establishments can adopt a variety of best 

management practices or install interceptor/collector 

devices to control and capture the FOG material before 

discharge to the POTW collection system. 

For example, instead of discharging yellow grease to 

POTWs, food service establishments often accumulate 

this material for pick up by consolidation service 

companies for re-sale or re-use in the manufacture of 

tallow, animal feed supplements, fuels, or other 

products. 

Additionally, food service establishments can install 

interceptor/collector devices (e.g., grease traps) in 

order to accumulate grease on-site and prevent it from 

entering the POTW collection system. 

Office of Water 

EPA-833-F-12-003 

September 2012 

[This Fact Sheet replaces EPA-833-F-07-007, July 2007] 

3 
Office of Water 4 

EPA-833-F-12-003

September 2012

[This Fact Sheet replaces EPA-833-F-07-007, July 2007]

How should FSEs 

design and 

maintain their FOG 

controls? 

Proper design, installation, and maintenance procedures 

are critical for these devices to control and capture the 

FOG. For example, 

♦ Interceptor/collector devices must be designed and 

sized appropriately to allow FOG to cool and separate 

in a non-turbulent environment.

♦ FSE must be diligent in having their

interceptor/collector devices serviced at regular 

intervals. 

The required maintenance frequency for 

interceptor/collector devices depends greatly on the 

amount of FOG a facility generates as well as any best 

management practices (BMPs) that the establishment 

implements to reduce the FOG discharged into its 

sanitary sewer system. 

In many cases, an establishment that implements BMPs 

will realize financial benefit through a reduction in their 

required grease interceptor and trap maintenance 

frequency.

What are some 

POTWs doing today 

to control FOG 

discharges from 

FSEs? 

A growing number of control authorities are using their 

existing authority (e.g., general pretreatment standards 

in Part 403 or local authority) to establish and enforce 

more FOG regulatory controls (e.g., numeric 

pretreatment limits, best management practices 

including the use of interceptor/collector devices) for 

food service establishments to reduce interferences with 

POTW operations (e.g., blockages from fats, oils, and 

greases discharges, POTW treatment interference from 

Nocardia filamentous foaming, damage to collection 

system from hydrogen sulfide generation).

For example, since identifying a 73% non-compliance 

rate with its grease trap ordinance among restaurants, 

New York City has instituted a $1,000-per-day fine for 

FOG violations. 

Likewise, more and more POTWs are addressing FOG 

discharges by imposing mandatory measures of 

assorted kinds, including inspections, periodic grease 

pumping, stiff penalties, and even criminal citations for 

violators, along with ‘strong waste’ monthly surcharges

added to restaurant sewer bills. Surcharges are 

reportedly ranging from $100 to as high as $700 and
Office of Water 5 

EPA-833-F-12-003

September 2012

[This Fact Sheet replaces EPA-833-F-07-007, July 2007]

more, the fees being deemed necessary to cover the 

cost of inspections and upgraded infrastructure. 

Pretreatment programs are developing and using 

inspection checklists for both food service 

establishments and POTW pretreatment inspectors to 

control FOG discharges. Additionally, EPA identified 

typical numeric local limits controlling oil and grease in 

the range of 50 mg/L to 450 mg/L with 100 mg/L as the 

most commonly reported numeric pretreatment limit.

Where can I get 

more information?

Report to Congress: Impacts and Controls of CSOs and 

SSOs, EPA-833-R-04 001, August 2004, 

http://cfpub.epa.gov/npdes/cso/cpolicy_report2004.cfm

Local Limits Development Guidance, EPA-833-R-04-

002A, July 2004, and EPA’s Pretreatment Web site, 

http://cfpub.epa.gov/npdes/home.cfm?program_id=3

CMOM information is located in the following document, 

Guide for Evaluating Capacity, Management, Operation, 

and Maintenance (CMOM) Programs at Sanitary Sewer 

Collection Systems, EPA-305-B-05-002, January 2005, 

http://www.epa.gov/npdes/pubs/cmom_guide_for_colle

ction_systems.pdf

Additional information is also available from your state 

or EPA Region.