National Fire Prevention Association (NFPA) 96 Standard

The National Fire Prevention Association developed NFPA 96 for Ventilation Control and Fire Protection of Commercial Cooking Operations. According to the document scope found at www.nfpa.org, "this standard shall provide the minimum fire safety requirements (preventative and operative) related to the design, installation, operation, inspection, and maintenance of all public and private cooking operations. These requirements include, but are not limited to, all manner of cooking equipment, exhaust hoods, grease removal devices, exhaust ductwork, exhaust fans, dampers, fire-extinguishing equipment, and all other auxiliary or ancillary components or systems that are involved in the capture, containment, and control of grease-laden cooking effluent."

While this standard is good at preventing fires, it's not intended to prevent environmental problems. The standards which specifically target environmental issues are put out by the Environmental Protection Agency (EPA). The NFPA 96 Standard outlines sound criteria for a grease collection system and to what standards components of the system must be cleaned.

However, NFPA 96 does not outline how to dispose of the collected grease in a way that adheres to EPA guidelines. Once the grease is collected, it is the responsibility of the establishment to abide by EPA standards.

EPA FOG (Fats, Oils, and Grease) Standards

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."
Click to read: Impacts and Controls of CSOs and SSOs, EPA-833-R-04 001, August 2004.

FOG wastes are generated at food service establishments as byproducts of food preparation. FOG captured on-site is generally classified into two broad categories:

How do Publicly Owned Treatment Works (POTWs) know if they have FOG issues?

POTWs use Geographic Information System mapping to both inventory and locate entities that produce FOG constituents. That information, paired with a complaint database that notes when FOG is responsible for blockages, is a powerful tool to assess problems and develop solutions. With knowledge of the sources and 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.

Capacity, Management, Operations, and Maintenance (CMOM) programs help control FOG discharges

The 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 food service establishments 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.

How should food service establishments design and maintain their FOG controls?

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 interference 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.

Helpful Resources

Restaurant Grease: Know Your Environmental Regulations
published by Ohio EPA