The Half of the Job That Is Filing

What comes back from a service

A ticket or manifest: the date, who did it, the device, how much was removed, and where the waste went. Keep it. It is the only evidence that a service happened and the only way to show a pattern over time.

Check it before the truck leaves, because a manifest with the wrong device or a blank volume is a document that proves nothing.

What a program is tracking about you

EPA’s material lists what control authorities keep on each establishment: ownership and contact details, the address and its location in the sewer system, inspection history with photographs and findings, correspondence and notices, the type, size and certification of the grease control equipment, the hauler agreements and certifications, permits, and blockages traced by location and cause.

Most of that list is a copy of something you also hold. The difference is that theirs is organized.

Source: U.S. EPA, FOG Management and Control Program.

What an inspection looks at

EPA’s material is explicit that an inspection is not just measuring the depth in the vessel. It includes a check of the grease control equipment, visual observation at the establishment itself, and checks of the downstream manhole.

That last one is the one people forget: what is in the sewer past your connection is evidence about your kitchen, and it does not care what your records say.

How enforcement escalates

Noncompliance notification, notice of violation, schedule of compliance, administrative order, administrative penalty — applied according to severity and to whether it has happened before.

The practical consequence is that the first letter is the inexpensive one. Responding to a noncompliance notification with a corrected schedule and the manifests to back it up is an entirely different position from arriving at the same conversation two letters later.

The nine elements, briefly

A FOG control program, in the framework EPA describes, has legal authority through a sewer use ordinance, plan review and design standards, inspections, a permitting or control mechanism, enforcement, communication, performance measures, public education and an information management system.

Knowing the shape of it tells you which door to knock on: design questions go to plan review, schedule questions to the permit, and a letter goes to enforcement.

• The local rule
• How often