The following actions are recommended in the establishment of the FOG Best Management Practices:

• At the outset food service employees need to be educated and trained in critical FOG disposal procedures. Such procedures must be reinforced and sustained with uncompromising consistency. Best practices need to be shared with all food preparation personnel in order to develop awareness in chefs, cooks, kitchen help and servers. Such reinforcement must be ongoing and occur on a regular basis. Consistent adherence to the proper disposal procedures should become an expectation of all employees in the exercise of their routine work responsibilities. Exposure to such expectations needs to become an integral part of the orientation of all new employees.

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• Too great a volume of FOG discharged from kitchens is routinely routed into the sewer system via poor sink disposal practices. To curb any potential problems, screens and strainers need to be installed on all kitchen sink drains. The same should be established for any existing floor drains. Strainers provide an easily maintained system for preventing a myriad of food solids from entering the waste stream.  If any established grease control device becomes filled even in part with volumes of food solids, it will lose its capacity to retain grease.  

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• It should be determined whether or not kitchen fixtures are appropriately FOG bearing. There is a rather simple means for making such determination. It is a matter of determining the nature of the fixture’s usage. For example, disposal activities related to rinsing or washing dishes, pots or pans and other kitchen utensils obviously involve the regular disposal of grease bearing product. The need for well- maintained strainer systems on these fixtures is imperative. On the other hand, food prep sinks usually employed to wash and prepare fruits and vegetables are not going to generally produce large volumes of grease saturated disposal matter.   Therefore, they are of lesser concern unless occasionally large volumes of fruit or potato peels are being jammed into the strainer-less drain. Further, if sinks happen to have multiple usages such as preparing raw chicken and salad ingredients, the potential of multiple problems is rather obvious. There is the immediate danger of transmitting salmonella poisoning to guests as well as the creation of unwanted grease clogs.  In such cases, it is likely that both food preparation regulations and grease disposal guidelines are being violated.

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• Before any sink used for rinsing dishes or washing pots and pans is drained, any accumulated free-floating oil and fats should be skimmed and removed to grease disposal containers. Any water discharged above 140 degrees is going to emulsify grease. Therefore, dishwashers should not be connected to a line feeding any grease control device.

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• Proper dish washing procedures significantly reduce entry of FOG and other waste material into the sewer system. Recommendations for proper food waste disposal and rinse/wash water temperatures need to be clarified. Before washing dishes or cooking utensils, accumulated food waste and solidified FOG should be scraped from their surfaces. Pots, pans, fryers, and cooking utensils, screens should then be dry wiped directly into trash containers.  Rubber scrapers, squeegees, or spatulas may be employed for scraping food into the trash.

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• Kitchen exhaust system filters and floor mats should be cleaned in utility sinks or other designated areas connected directly to a grease control device.  They should not be cleaned in an area where wastewater can flow to a gutter, storm drain, or street surface so the discharge does not enter storm sewer system. If the food service establishment employs a private sector company to collect the grease water and remove it from the site, it remains the responsibility of the food service establishment to ensure that the company is disposing the collected greasy water in accordance with all State and Local Guidelines. If this company is located within the food service establishment regulated authority area, it is worth arranging to observe the disposal company’s final disposition procedures in order to avoid any involvement in a violation over which the food service establishment does not have direct control.

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• Deliberate efforts must be made to avoid spills in kitchen areas. If spills should occur, immediate steps must be implemented that avoid the risk of FOG entering floor drains. Spill clean-up should include immediately blocking off sink and floor drains near the spill and cleaning spills with towels or other absorbent material.  Spills of dry ingredients should be swept or vacuumed to prevent them from being washed into floor drains.

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• Covers should be placed on containers before oil or grease is transported to recycling barrels.  Employees should be provided with appropriate containers designated for this purpose. When changing yellow oil in fryer units, the oil should be drained into a bucket and discarded into containers that will be hauled away. Fryer oil should never be discharged into a grease interceptor or waste drain. Additionally, grill top scrap baskets should be emptied or scrapped into the rendering barrel.

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• Outdoor oil and grease containers must be covered to prevent the intrusion of rainwater. This prevents floating FOG from overflowing onto the ground where it can potentially reach the storm water system. FOG rendering containers should be located as far from storm drains as possible to further reduce the potential of inadvertent storm drain entry.