Grease Contractors Association                            WQR0083


Written evidence from the Grease Contractors Association




Dear Rt Hon Philip Dunne,

The Grease Contractors Association (GCA) welcomes the Sewage (Inland Waters) Bill and was pleased to see reference made to the disposal of fats and oils into sewers by food service establishments (FSEs).


Administered by British Water, the GCA is a non-profit organisation of specifiers, installers and maintainers of grease management systems which is working with the hospitality industry, legislative and regulatory bodies and academic bodies to bring collaborative change related to the management of fat, oil and grease (FOG).


The last few years have seen sustained growth in the food service industry with more restaurants and takeaways opening in city centres across the UK. In the current pandemic we have also seen a significant rise in professional kitchens that only produce food for delivery – often referred to as dark kitchens.


This denser concentration of FSEs, along with legacy combined sewer networks, are contributing to a greater build- up of FOG in wastewater systems. This, combined with more frequent and intense rainfall events as a result of climate change, is leading to more cases of severe sewer flooding and pollution incidents. It is known now that FOG-related sewer blockages and pumping station failures are a far greater cause of flooding and pollution than heavy rain alone.


Our objectives are to reduce FOG in sewers, educate consumers and operators, carry out research on recycling FOG, influence standards and inform the legal framework. We aim to create an environment for FOG to be controlled at source and to improve equipment selection, installation and maintenance.


There is still a long way to go - much is needed to be done to educate and support the producers of FOG, develop new products and treatment processes and ensure the right legal framework is in place.


While UK water companies have been running domestic customer engagement campaigns around FOG management some time, we believe there is still a lack of awareness in the food service industry. There is confusion around legislation, standards and appropriate products, heightened by a lack of unified approach from the industry.


Currently, there is no legislation requiring the fitting of grease management in an FSE/commercial kitchen.


          Planning legislation – Part H1 Building Regulations Section 2.2: ‘Drainage serving kitchens in commercial hot food premises should be fitted with a grease separator complying with EN 1825-1 and designed in accordance with EN 1825-2 or other effective means of grease removal’. The lack of an absolute obligation suggesting discretion and the lack of a clear definition of ‘effective means’ has not encouraged adoption in commercial kitchens.




Grease Contractors Association                            WQR0083

          Water Industry Act, Section 111: ‘It is a criminal offence under section 111 of the Water Industry Act 1991 to discharge into the public sewers any matter which may interfere with the free flow of wastewater’. This has been used to ‘encourage’ change and, if necessary, to force change through prosecution but it is extremely difficult for water companies to gather evidence of the offence.


          Standards: There is no ‘Standard’ in the UK for Grease Management Equipment. The only standard is BS EN 1825:2004 – Grease separators. Principles of design, performance and testing, marking and quality control. This standard only refers to one type of Grease Management Equipment: Passive Traps. Although the standard is referenced in the planning legislation, the standard has not been adopted in the UK. Mainly because of the use of marine diesel for testing (which may not recreate the kitchen conditions) and the lack of independent testing facilities. Currently, there is no standard in the UK for Grease Removal Units and Biological Dosing Systems


The GCA views the inclusion of prohibiting the disposal of fats and oils into sewers by food service establishments in the Sewage (Inland Waters) Bill, as a step change that could bring to the industry:


-          Action to put adequate systems in place

-          Education for FOG producers on how to deal with the problem (operational procedures, maintenance, responsibilities, behaviour)

-          Innovation to develop new products and treatment processes

-          Collaboration to bring a unified approach across the country


To help to push this change, the GCA has produced new Grease Management Equipment Guidance for FSEs. The guide provides an overview of the specification, supply, installation, and maintenance of all types of grease management equipment, with the aim of educating, informing and encouraging action among users.



Yours Sincerely,


Lila Thompson

British Water Chief Executive Grease Contractor Assocation Chair


March 2021