FOG Compliance Checklist
A complete fats, oils, and grease compliance checklist for commercial kitchens. Work through all five compliance areas, track your progress, and print a completed record for your FOG binder or health department inspection.
Be Ready Before an Inspector Arrives
FOG compliance inspections are typically unannounced. Inspectors from your local sewer authority or health department can request to see your grease trap, your service records, and your waste manifests at any time. Operators who can produce a complete, organized compliance record on the spot rarely receive fines. Operators who can't often do — even when the underlying work was done correctly.
This checklist covers all five compliance areas: trap installation and sizing, cleaning frequency and documentation, waste manifest records, best management practices (BMPs), and staff training. Check each item off as you verify it. When complete, print the page for your FOG compliance binder.
Note: This checklist reflects common requirements across US and Canadian FOG ordinances. Your specific jurisdiction may have additional requirements. When in doubt, contact your local sewer authority or municipal FOG coordinator for the applicable ordinance.
FOG Compliance Checklist
Check each item to track your compliance status. Progress saves while you work.
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What FOG Inspectors Actually Look For
Municipal FOG inspectors vary in how they conduct inspections, but the core documentation request is consistent across jurisdictions: they want to see that your trap is properly sized, being cleaned on schedule, and that you have the paperwork to prove it. A well-maintained binder with organized service reports and waste manifests communicates competence and good faith — inspectors are human, and paperwork demonstrating proactive compliance changes the tone of an inspection.
The most common violations found during inspections are not catastrophic failures. They're documentation gaps: missing waste manifests, service reports with incomplete information (no gallons removed, no before/after measurements), or cleaning intervals that have slipped by a few weeks without a written reason. These are easy to fix before an inspection and costly to explain during one.
The BMP section of this checklist is frequently overlooked. Enzyme additives are sold aggressively to restaurant operators as a way to reduce cleaning frequency — but every major FOG ordinance prohibits them because they liquefy FOG and push it downstream into the sewer, exactly the problem the ordinance exists to prevent. An inspector who finds enzyme additive products in your kitchen or on your invoices will treat it as a violation regardless of your cleaning records.
FOG Compliance — Common Questions
Based on common municipal FOG ordinance requirements across the US and Canada.
It varies significantly by jurisdiction. Some municipalities inspect all food service operations annually; others only inspect in response to complaints or sewer blockage events traced to a specific area. High-risk operations (large volume, history of violations) are inspected more frequently. In jurisdictions with active FOG programs like NYC, LA, and Dallas, inspections can happen without advance notice at any time the kitchen is operating. The safest assumption is that your documentation could be requested any day.
First-time violations for documentation issues (missing records, incomplete service reports) typically result in a corrective action notice with a 30-day cure period rather than an immediate fine. Operational violations — trap above 25%, FOG discharge to sewer, prohibited enzyme use — typically carry fines of $200–$2,000 per incident depending on jurisdiction. Repeat violations escalate quickly, and some municipalities have the authority to suspend food service permits for persistent non-compliance. Sewer backup damage caused by FOG can result in cost-recovery actions in the tens of thousands of dollars.
Rarely, and only in specific jurisdictions that have reviewed and approved specific products. The vast majority of US and Canadian FOG ordinances explicitly prohibit the use of enzymes, solvents, emulsifiers, and biological additives in grease traps because they liquefy FOG and pass it into the sewer — defeating the purpose of the trap. Some jurisdictions allow approved biological treatments as a supplement to (not replacement for) regular mechanical cleaning. Never use additives without first confirming with your local sewer authority that the specific product is permitted.
Most FOG ordinances apply to any food service establishment that discharges to the municipal sewer — including cafes, bakeries, and food trucks with a commissary connection. The threshold is typically any operation that prepares or serves food using cooking processes that generate FOG. Low-volume operations may qualify for a passive under-sink trap rather than an outdoor interceptor, and cleaning intervals may be less frequent — but the documentation requirements (service records, waste manifests, BMP compliance) generally apply regardless of size. Check your local ordinance for any small-establishment exemptions.
Respond within the timeframe specified — typically 30 days for a corrective action notice. Schedule immediate cleaning if the violation involved trap condition. Assemble your compliance documentation (service records, manifests, schedule) and submit a written response demonstrating corrective action taken and the steps you've put in place to prevent recurrence. Municipalities respond well to operators who engage proactively. If the violation involves a fine, you typically have the right to request an administrative hearing — document everything and attend prepared with your compliance binder.
Need a Compliant Contractor?
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