What FOG (Fats, Oils, Grease) Rules Mean for Your Business

FOG rules turn your kitchen’s grease into a set of standing obligations you have to meet every day, not a one-time install. In practice they require four things from you: keep the fats, oils, and grease your kitchen produces out of the sewer below a discharge limit, run specific best management practices in the dish pit, hold a permit or registration with your sewer authority, and keep records that prove all of it when an inspector asks. Miss any one of those and you can be cited even if your interceptor is sitting in the ground exactly as designed.

This guide is your obligation checklist: the limits, the daily practices, the paperwork, and what an enforcement notice looks like. It does not cover why the requirement exists or who has the legal power to impose it, which is traced in our guide on why restaurants are required to have grease interceptors (220). For the maintenance interval and the cleaning math, see our guide on how often a grease trap needs cleaning (221). For choosing the right unit size during a build-out, see our guide on how grease interceptors are sized for a commercial kitchen (223). Here the focus stays on what you are accountable for once the device is in.

What a Local FOG Program Actually Requires of You

A FOG program imposes ongoing duties, and they almost always come from your local sewer-use ordinance rather than a single national rule. The U.S. Environmental Protection Agency runs the National Pretreatment Program, which gives publicly owned treatment works the authority to control what nondomestic sources like restaurants put into the sewer. The federal layer sets the floor. Your specific obligations get written into a local ordinance and FOG control program by your sewer district, so the exact numbers and forms differ from one city to the next.

Strip away the local variation and the same core duties show up almost everywhere. You install and keep an approved grease removal device on the right drain lines. You operate so that the grease leaving your property stays under the program’s limit. You follow required kitchen practices that keep grease out of the drain in the first place. You hold whatever permit or registration the authority requires. You let inspectors in and show them records on demand. Those five duties are the spine of compliance, and the rest of this guide walks through each one.

Because the binding text is local, the only way to know your exact obligation is to read your own sewer authority’s FOG ordinance or call the office that runs it. A national overview can tell you the shape of the program. It cannot tell you your city’s discharge limit, your registration deadline, or how long you must keep your manifests.

Discharge Limits and the Best Management Practices Behind Them

A discharge limit caps how much grease your wastewater can carry as it leaves your property, usually expressed as a concentration in milligrams per liter. Many programs set a numeric FOG limit at the connection to the public sewer, and the specific number is set locally, so you confirm yours with your sewer authority. The reason the limit exists sits in federal law: the EPA’s general pretreatment regulations specifically prohibit “solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW resulting in Interference.” Hardened grease that coats a sewer main is the textbook example of that prohibited discharge, and your local FOG limit is how the authority makes that prohibition measurable for your business.

Your interceptor does the heavy lifting on that limit, but it cannot do the job alone. That is why programs pair the limit with best management practices, the day-to-day kitchen habits that keep grease out of the drain before it ever reaches the device. EPA and local FOG materials describe a consistent set of these practices:

• Scrape and dry-wipe pots, pans, plates, and fryer areas into the trash before anything goes near a sink. Dry cleanup keeps grease out of the water stream entirely.
• Never pour grease, fryer oil, or greasy liquids down a drain or floor sink. Collect used cooking oil in a dedicated container for a rendering or recycling pickup.
• Put strainers or baskets over every drain to catch food solids, and empty them into the trash, not the sink.
• Wipe greasy surfaces with paper towels that go in the trash rather than rinsing them into the drain.
• Train kitchen staff on these steps and post reminders, since the practices only work when every shift follows them.

These habits matter for compliance, not just housekeeping. Dry cleanup and scraping can cut the grease load reaching your interceptor substantially, which keeps your discharge under the limit and stretches the time between cleanings. Some ordinances list specific BMPs you are required to follow and can cite you for ignoring, so check whether yours treats them as recommendations or as rules.

Permits, Registration, and Inspection Visits

Most FOG programs require you to be on the authority’s books before you operate, through a permit, a registration, or a wastewater discharge authorization for food service establishments. The document ties your business to the program: it identifies your grease removal device, sets your obligations, and gives the authority a record to inspect against. Some programs issue these for a multi-year term and require renewal. The requirement often surfaces during permitting for a new build-out or remodel, because plan reviewers want to see grease control on the plumbing drawings before the work passes inspection.

Once you are registered, expect inspections. Under the federal pretreatment rules, the control authority must carry out the inspection and surveillance needed to determine compliance independent of what you report, which is why an inspector can show up and look for themselves. A FOG inspection typically checks that your device is installed and functioning, that grease is not breaking through to the sewer, and that your records are current and complete. The inspector may open the interceptor to gauge how full it is, ask for your service history, and confirm you are using a permitted hauler.

The practical takeaway is that an inspection is a paperwork event as much as a plumbing event. A clean, well-maintained interceptor still fails if you cannot produce the records that prove it stays that way. Treat inspection readiness as a standing condition, not something to scramble for when the letter arrives.

Recordkeeping: Manifests, Logs, and What Inspectors Check

Recordkeeping is where many otherwise-compliant kitchens get cited, because the device can be fine while the file is empty. The central document is the service manifest, the receipt a licensed hauler gives you each time the interceptor is pumped or cleaned. A complete manifest generally identifies your business as the generator, names the hauler, states the service date and the volume of waste removed, and shows the approved disposal facility where it went. Keep every one.

Beyond the manifests, programs commonly expect a maintenance log showing the dates of each cleaning and any device service, plus proof that your hauler is licensed or permitted to transport and dispose of grease waste. Some authorities require you to submit cleaning reports on a schedule rather than just hold them. How long you must retain the records varies by jurisdiction, and three years is a common floor, though some programs require longer, so confirm the retention period in your ordinance.

When an inspector reviews your file, they are answering a few questions: Is the device being serviced on the required schedule? Is the volume removed consistent with a unit that is actually being maintained? Did a licensed hauler do the work and take it to an approved site? Missing manifests, gaps in the service dates, or an unpermitted hauler can each turn into a finding, even when the interceptor itself looks fine. The records are how you prove compliance, so a disciplined filing habit protects you as much as the cleaning does.

Violations, Notices, and Penalties for Non-Compliance

Enforcement usually starts with a notice rather than a fine. A notice of violation tells you what failed, whether that is an over-limit discharge, an overdue cleaning, missing records, or an unpermitted hauler, and gives you a window to correct it. Ignore it or repeat the problem and the authority escalates to monetary penalties, compliance orders, and in serious or repeat cases steps that can affect your ability to keep operating. A neglected interceptor can also back grease up into your own kitchen, which can force a temporary closure on its own.

Federal law sets a floor for how hard the local authority can hit. The EPA’s pretreatment regulations require every control authority to have the legal power to seek or assess civil or criminal penalties of “at least $1,000 a day for each violation” by industrial users of pretreatment standards. That is the minimum authority the local program must hold, not a flat fee you will necessarily be charged. Actual penalty amounts, schedules, and escalation steps are set by your local ordinance and vary widely, so the real number that applies to you lives in your sewer authority’s enforcement response policy.

A second enforcement layer can come from your local health department, since food-facility codes often touch the condition of plumbing and grease handling. A failing or filthy interceptor can draw a health-code citation even though the discharge itself is the sewer authority’s jurisdiction. The cleanest way to avoid all of it is to treat the limit, the practices, the permit, and the records as a single ongoing routine rather than separate boxes to check once.

Frequently Asked Questions

What is the difference between a FOG rule and the requirement to have a grease trap?
Having a grease removal device is one piece of a FOG program. The rules also govern how much grease your wastewater can carry, what kitchen practices you must follow, what permit or registration you hold, and what records you keep. The device is the hardware; the FOG rules are the full set of operating obligations around it.

Is there a single national FOG limit my business has to meet?
No. Federal pretreatment law prohibits discharges that obstruct the sewer and gives local treatment works the authority to control them, but the specific numeric limit, the required practices, and the paperwork are set by your local sewer-use ordinance. Your exact limit comes from your sewer district or wastewater utility, not from a national standard.

What records do I actually need to keep?
At a minimum, keep the service manifests from every interceptor cleaning, a log of service dates, and proof that your hauler is licensed. Manifests should show the generator, the hauler, the service date, the volume removed, and the disposal site. Retention periods vary by jurisdiction, with three years a common minimum and some programs requiring longer.

Can I be fined if my grease trap is installed correctly but I have no records?
Yes. Many violations are about documentation and practices, not just hardware. An inspector who cannot see current manifests, a maintenance log, or proof of a licensed hauler can issue a finding even if the device is physically fine. The records are how you demonstrate ongoing compliance.

How do I find the rules that apply to my specific business?
Start with your local sewer district, wastewater utility, or publicly owned treatment works, which runs the FOG program and writes the binding ordinance. Then check your local health department for any food-facility plumbing rules layered on top. Local code, not a national page, sets your discharge limit, your permit terms, and your recordkeeping duties.

This article is general information, not professional or legal advice. Confirm the FOG requirements that apply to your business with your local sewer authority and health department, and have a licensed plumber service your grease removal device.

Sources

• U.S. EPA, National Pretreatment Program Implementation: https://www.epa.gov/npdes/national-pretreatment-program-implementation
• U.S. EPA, Pretreatment Standards and Requirements: General and Specific Prohibitions: https://www.epa.gov/npdes/pretreatment-standards-and-requirements-general-and-specific-prohibitions
• eCFR, 40 CFR 403.5 (National Pretreatment Standards: Prohibited Discharges): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-403/section-403.5
• eCFR, 40 CFR 403.8 (Pretreatment Program Requirements: Development and Implementation by POTW): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-403/section-403.8
• U.S. EPA, Fats, Oils, and Grease: What We Know After 23 Years of FOG Work: https://www.epa.gov/compliance/fats-oils-and-grease-what-we-know-after-23-years-fog-work
• U.S. EPA, Controlling Fats, Oils, and Grease Discharges from Food Service Establishments: https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P10099TU.TXT