Water Services Training Group

WRc FOG Project

Legislation and Licensing

WRc FOG ProjectLegislation and Licensing

Andy Drinkwater

FOG Programme Manager

WRc

WRc FOG Project A co-ordinated three year investigation,

involving sewer system operators in the Republic of Ireland and the UK.

Look at ALL aspects of FOG in the sewer system AND related issues

Previously there had been various short term and very specific studies by various organisations (very limited success)

WRc FOG Project Work Package 1: Legal – legislation / regulations/

licensing – case files/customer letters (FOG letters)

Work Package 2: Sociological – dealing with dischargers/ customer

Work Package 3: Biological/chemical – FOG compound, dosing methods etc

Work Package 4a: Engineering – designing FOG out (sewers/ pumping stations, grease separators)

Work Package 4b: Operations – cleaning techniques etc (sewers/ pumping stations)

WRc FOG Project – Aims (1)

Identify potential sources of FOG Investigate the effect of FOG in:

Private and public drains/sewers Pumping stations Wastewater Treatment Works – as far as

the primary settlement tanks

Better understand the FOG compound(s) Consider disposal options for FOG

WRc FOG Project – Aims (2)

Better understand how the design and operation of the sewer system affects the accumulation of FOG

Review legislation/licensing issues Evaluate a range of methods to minimise the

FOG problem – stopping FOG being discharged to sewer

Change peoples habits to reduce FOG being disposed of into the drainage system

Reducing FOG problem Need to understand FOG problems within a

catchment – need sufficient information to identify cause, not just the symptom

Need to consider solutions to FOG problems: Always include reducing FOG load at

source. May include improvements in the sewer

system

WRc FOG Project – Outputs

Methods and procedures enabling sewer system operators to better deal with the FOG problem

Focus on commercial premises, especially food/catering establishments

Incorporate: Legal and social aspects FOG management products (through trials) Operational procedures Design concepts

WRc FOG Project Work Package 1: Legal – legislation /

regulations/ licensing – case files/customer letters (FOG letters)

Work Package 2: Sociological Work Package 3: Biological/chemical Work Package 4a: Engineering Work Package 4b: Operations

FOG Work Package 1 - Deliverables

FOG strategy – method to record information in a ‘case file’, suitable should prosecution become necessary

Reviews of relevant legislation (Report P7540)

Customer letters (FOG letters)

Legislation and licensing – reducing FOG load

Change peoples habits to reduce volume of FOG disposed of to sewer, mainly through education and persuasion Better kitchen practice FOG removal – grease separators and/or

dosing systems – where appropriate, give advice

Need to take legal action if all else fails (threat usually sufficient)

Legislation and licensing – persuading the customer

Leaflets – better kitchen practice, FOG handling and disposal

Guides – e.g. grease separators Licensing, to include method based consents:

Used in Sydney, Australia Use of consents - Grease separator

location, size, maintenance, disposal routes

Alternatively, biological dosing requirements/ methodology

Legislation and licensing – Available legislation

Local Government (Water Pollution) Act 1977 – section 16

Circular L8/03 (WSP) Water Services Act 2007 – Section 63

Legislation and licensing – legal action (1)

In most cases persuasion and repeated visits will work. Need to be able to threaten legal action, if all else fails

Historically, been a problem to: Identify who caused the problem – many

food outlets (potential offenders) close together

Specify a discharge standard Police – sampling not practical

Need to gain evidence

Legislation and licensing – legal action (2)

Identify who caused the problem: Gain access to premises Use of ‘look see’ cameras Gather and record information

Discharge standard: Where appropriate, use of method based

consents Policing;

Spot checking for license compliance

FOG Work Package 1 - Deliverables

FOG strategy – method to record information in a ‘case file’, suitable should prosecution become necessary

Reviews of relevant legislation (Report P7540)

Customer letters (FOG letters)