Clearing the FOG away
High maintenance costs have inspired Dublin City Council to go to war on FOG. The programme, scoped out by Compliance Consulting, has brought change to the drainage network
This experience – of the negative impacts of FOG – is not unique to Dublin but is shared by operators of drainage networks and wastewater treatment plants throughout the world. Dublin took the first steps on this road back in 2004 when they engaged a company – Compliance Consulting – to carry out an initial scoping study to get a handle on the extent of the problem in the city centre area.
The scoping study identified the scale of the problem – only two out of two hundred premises had properly functioning and maintained grease trapping equipment. It was also of assistance when it came to implementing the main programme in so far as a quick check of premises included in the scoping study would confirm that the situation had not improved in the interim in these premises. This helped to refute claims that self-regulation – as opposed to regulation by the local authority – was a better solution.
Implementing the programme
It was decided in principle that FOG discharges from Food Service Establishments would be treated like any other trade effluent discharge. The normal way to control trade effluent discharges is via a trade effluent licence, issued under the Water Pollution Act.
This licence usually contains conditions limiting the quality and quantity of discharge. In the case of FOG, it was decided that a limit of 100 mg/ml would be a condition of every licence. Further conditions relate to record keeping by the FSE and the implementation of Best Management Practices within the FSE such as staff training, dry wiping of plates, FOG related signage, etc.
There is also an annual fee to be paid to the local authority to cover the cost of monitoring to ensure that the FSE is in compliance with the conditions of the licence. Having decided to control FOG discharges, DCC decided to outsource this contract and seek a service provider to carry out this work. DCC then had to go through the public sector procurement process, commencing with advertising the tender in the Official Journal of the European Union in December 2006 and culminating in the appointment of Compliance Consulting in December 2007.
The objectives of the programme were:
• Locate, identify and survey 2000 Food Service Establishments (FSE) to ascertain what level of FOG management – if any – they had in place
• Explain to the FSE operator the requirements for properly designed grease trapping equipment and Best Management Practices
• Issue licences to each FSE, under the Water Pollution Act
• Once licensed, carry out quarterly monitoring inspections on each FSE to ensure compliance with the conditions of the licence
Within the above overall objectives there were many intermediate steps which can turn out to be time consuming, such as advising and approving the design sizing of equipment, getting the FSE operator to actually apply for the licence, adjudicating on the merits and suitability of various different types of equipment. Due to the large scale, city wide nature of the work, the contract to deliver the programme was for a three year period with an option of extending it into a final, fourth, year.
As this was the first time such a programme had been attempted, much of the contractor’s time was taken up in the early stages in meeting with the various different stakeholders. This was an eye-opener in many respects as it quick became obvious that this industry was “sales-led” rather than science led. Aggressive solvents and chemicals were commonly used within an FSE as they produced very visibly clean results. However, as these products were mostly emulsifiers, they simply liquefied the FOG within the premises, enabling it to flow out to the public sewers where, on cooling, it would re-solidify and cause a blockage.
The challenge was to convince the FSE operator that his work practices, for which, incidentally, he was paying significant monies, were causing a problem. Another essential part of the work is the extent of record keeping necessary. Compliance Consulting record every interaction with an FSE, be it a site meeting, phone conversation, letter, email, fax, etc. A customised software package enables this information to be accessed instantly.
A clear communications strategy was required which included meetings with the representative organisations and the publication of information leaflets outlining facts about FOG.
Progress to date
The programme is now 20 months under way. To date the big picture results are:
• Compliance Consulting have achieved the contract target and carried out initial inspections on just over 2,000 premises
• DCC have issued new FOG licences to more than 1,500 premises
• Over 900 new, properly designed grease trapping devices have been installed
• Approximately 2,000 tonnes of waste FOG has been audited as pumped out of grease traps and disposed of in authorised facilities, rather than discharged down the drain
• Compliance Consulting has carried out over 6,000 monitoring inspections of premises