FOG Best Management Practices: The Complete BMP Framework for Commercial Kitchens

Fats, oils, and grease (FOG) best management practices (BMPs) are the operational framework that commercial kitchens use to prevent FOG from entering the municipal sewer system. Unlike one-time equipment installations, BMPs are ongoing administrative and operational controls — maintenance schedules, staff training protocols, record-keeping systems, and vendor management procedures. Local sewer authorities and the EPA consider a documented BMP plan essential to FOG compliance, and many jurisdictions make it a permit condition for food service establishments.

What Is a FOG BMP Plan?

A FOG BMP plan is a written document that describes how a food service facility prevents FOG discharges to the sanitary sewer system. It goes beyond having a grease trap or interceptor installed — it documents the systems, procedures, and accountability structures that ensure FOG control equipment is maintained and operated correctly.

Print our FOG Compliance Checklist and walk through it monthly with your kitchen lead.

The EPA's pretreatment program guidelines and most local FOG ordinances require commercial kitchens to implement BMPs as part of their operating permit. A well-constructed BMP plan serves three purposes:

• Regulatory compliance: Demonstrates to inspectors that the facility has a proactive FOG management program, not just reactive equipment.
• Operational consistency: Ensures FOG control practices continue even when staff turns over, which is frequent in foodservice.
• Liability protection: Provides documented evidence of due diligence if a FOG-related sewer backup or SSO (sanitary sewer overflow) is traced to the facility.

Required Elements of a FOG BMP Plan

1. Grease Interceptor/Trap Maintenance Program

The foundation of any BMP plan is a documented maintenance schedule for all FOG control devices. This includes:

• Pumping schedule: Frequency based on the 25% rule (pump when grease and solids reach 25% of liquid depth). Most facilities require service every 30–90 days, but high-volume kitchens may need weekly or bi-weekly service.
• Pump-out records: Every service event must be documented with the date, service provider name, volume pumped, grease thickness measurement before and after, and disposal manifest number.
• Inspection log: Regular visual inspections between pump-outs to check for grease cap buildup, odors, and structural integrity of baffles and seals.

For detailed guidance on maintenance scheduling, refer to the grease trap maintenance guide.

2. Kitchen Best Practices

Operational BMPs target FOG at the source — before it enters the drain system:

• Dry wipe before washing: All pots, pans, plates, and cooking equipment should be scraped and dry-wiped with paper towels before washing. This single practice removes the majority of FOG before it reaches the water stream.
• No oil down drains: Used cooking oil must be collected in designated containers and recycled through a UCO collection program, never poured into sinks or floor drains.
• Drain screen use: Install and maintain basket strainers or screens on all sink drains and floor drains connected to the grease interceptor to capture food solids.
• Proper dishwasher operation: Pre-rinse food scraps before loading. Ensure water temperature and detergent concentrations follow manufacturer specs — excessive detergent emulsifies grease and pushes it through the interceptor.
• Spill containment: Maintain spill kits near fryer stations and oil storage areas. Clean up grease spills with absorbent materials, not by hosing them into floor drains.

3. Staff Training Program

BMPs only work when kitchen staff execute them consistently. A compliant training program includes:

• Initial training: All new kitchen employees receive FOG awareness training during onboarding, covering why FOG management matters, what practices are required, and what actions are prohibited.
• Annual refresher: Documented annual retraining for all kitchen staff.
• Training records: Signed attendance logs with date, trainer name, and topics covered. Inspectors routinely ask for these records.
• Multilingual materials: Training materials available in the primary languages spoken by kitchen staff.

4. Vendor and Service Provider Management

Your BMP plan should document all third-party vendors involved in FOG management:

• Grease pumping service: Company name, contact information, contract terms, service frequency, and license/permit verification.
• UCO recycler: Collection company, pickup schedule, container specifications, and rebate terms.
• Plumbing contractor: Licensed plumber for interceptor repairs, inspections, and code compliance verification.

Use the grease trap service directory to find licensed pumping companies and service providers in your area.

5. Record Keeping and Documentation

Comprehensive records are the backbone of BMP compliance. Maintain the following for a minimum of three years (some jurisdictions require five):

• Grease trap/interceptor pump-out manifests
• Inspection logs (internal and third-party)
• Staff training attendance records
• Equipment repair and replacement records
• UCO collection receipts
• Correspondence with the local sewer authority
• Any violation notices and corrective actions taken

The FOG compliance checklist provides a structured template for tracking all required documentation.

6. Spill Prevention and Emergency Response

Your BMP plan must include procedures for responding to FOG spills and equipment failures:

• Spill response protocol: Step-by-step instructions for containing and cleaning grease spills using absorbent materials (not water).
• Equipment failure protocol: Who to contact if the grease interceptor overflows, backs up, or shows signs of structural failure. Include emergency plumber contact information and after-hours service provider numbers.
• Notification requirements: Most jurisdictions require facilities to notify the local sewer authority within 24 hours of a significant FOG discharge or equipment failure.

State-by-State BMP Variations

While the core elements above are universal, several states impose additional BMP requirements:

• California: Many California municipalities require a formal FOG Control Program permit, including a submitted BMP plan reviewed and approved by the local sewer agency. Los Angeles, San Francisco, and San Diego each have distinct BMP submission requirements.
• Texas: The Texas Commission on Environmental Quality (TCEQ) requires grease trap maintenance records as part of food establishment permitting. Major cities like Houston and Austin have detailed BMP ordinances that specify minimum interceptor sizes, pumping frequencies, and inspection schedules.
• Florida: Florida DEP requires FOG BMPs as part of the industrial pretreatment program. Jacksonville, Tampa, and Miami-Dade County each enforce local FOG ordinances with specific BMP documentation standards.
• New York: New York City's DEP has one of the most detailed FOG BMP programs in the country, requiring registered grease interceptors, quarterly pump-out minimums, and submission of maintenance logs to the city.

For state-specific FOG requirements, visit the regulations hub.

How to Create Your BMP Plan

1. Audit current practices: Document what FOG management procedures your facility already follows. Identify gaps against the required elements listed above.
2. Assign responsibility: Designate a FOG compliance manager — typically the kitchen manager or facility manager — who owns the BMP plan and ensures all elements are executed.
3. Draft the plan: Create a written document covering all six elements. Keep it practical and specific to your facility — generic templates rarely satisfy inspectors.
4. Implement and train: Roll out the plan with staff training. Post key procedures (drain screen maintenance, dry-wipe protocol, spill response) in the kitchen as visual reminders.
5. Review and update: Review the BMP plan at least annually, or whenever there is a change in kitchen equipment, menu, service volume, or local regulations.

Frequently Asked Questions

Is a FOG BMP plan legally required?

In most jurisdictions, yes. Local FOG ordinances typically require food service establishments to implement and document BMPs as a condition of their sewer discharge permit. Even in areas without an explicit BMP mandate, having a documented plan provides significant protection during enforcement actions.

Who is responsible for maintaining the BMP plan?

The facility owner or operator bears legal responsibility for FOG compliance. In practice, the day-to-day management of the BMP plan is typically delegated to the kitchen manager or facility manager, but the owner remains the accountable party during regulatory enforcement.

How often should the BMP plan be updated?

Review the plan at least annually. Additionally, update it whenever there is a significant change: new kitchen equipment, menu modifications that alter FOG generation, changes in service providers, new local regulations, or after any FOG-related violation or incident.

What happens if I don't have a BMP plan during an inspection?

Consequences vary by jurisdiction but typically include a notice of violation, a compliance timeline to submit a plan (30–90 days), and potential fines for non-compliance. Repeat violations can escalate to increased inspection frequency, mandatory equipment upgrades, or — in extreme cases — permit revocation.

Can I use a template for my BMP plan?

Templates are a useful starting point, but most inspectors expect facility-specific details: your actual equipment list, your specific pumping schedule, your named vendors, and your real training records. A generic template without customization is unlikely to satisfy a thorough inspection. Start with the FOG compliance checklist and build your plan around your facility's actual operations.

Author: Grease Trap Locator Editorial Team

The Grease Trap Locator editorial team covers FOG compliance, grease trap maintenance, and commercial kitchen regulations across the US and Canada. Our guides are written for restaurant owners, facility managers, and food service operators who need practical, accurate information without the fluff.