1. Water Services Training Group WRc FOG Project Legislation and Licensing

2. WRc FOG Project Legislation and Licensing Andy Drinkwater FOG Programme Manager WRc

3. 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)

4. 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)

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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)

11. 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)

12. 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

14. Legislation and licensing – Available legislation  Local Government (Water Pollution) Act 1977 – section 16  Circular L8/03 (WSP)  Water Services Act 2007 – Section 63

15. 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

16. 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

17. 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)