FOG Pretreatment Programs for Texas Restaurants and Food Service Facilities

Why does grease cause real problems in a sewer?

Because it hardens as it cools and closes the pipe. Grease that is liquid at cooking temperature cools in the line, sticks to the pipe wall and narrows the pipe with every discharge.

The result is blockages. A blocked sanitary line does not just back up into the kitchen that caused it. It can back up into neighbors, and in worse cases it causes a sanitary sewer overflow to the ground or a waterway.

Grease also drives odor complaints and recurring cleaning for the utility. The federal pretreatment rules at 40 CFR 403.5 bar any user from discharging pollutants that cause interference, including solid or viscous pollutants that obstruct flow. Utilities with pretreatment programs must develop and enforce local limits to carry that out.

Who regulates FOG in Texas?

The city or utility regulates the trap; TCEQ regulates the waste. TCEQ's guidance on waste from grease traps (RG-389, revised August 2026) says grease trap authorization and installation are regulated by local ordinances, the local wastewater utility, or both.

TCEQ regulates the pumping, transportation, use and disposal of grease trap waste under 30 TAC Chapter 312, and facilities that process it under Chapter 330. Grease traps do not register with TCEQ, though a local authority may require registration.

The same guidance says a grease trap is required for any facility whose business produces cooking grease or oil that could reach the sewer, in areas that have adopted a plumbing code. For how a city's program fits under its pretreatment authority, see our post on pretreatment program delegation.

How does a FOG program work day to day?

It centers on the interceptor, then on proof that it is maintained. The grease interceptor sits between the grease-producing fixtures and the sewer connection and holds grease long enough to separate.

Sizing follows the plumbing code the city has adopted or the utility's FOG ordinance. It typically considers the number and type of connected fixtures, expected flow and the retention time needed for separation.

Ongoing compliance usually runs through:

• a pumping schedule set by the ordinance or by the interceptor's capacity
• trip tickets, also called waste manifests, for every pump-out
• maintenance logs
• a sampling or inspection point for the utility
• inspections, with enforcement when a facility fails one or is tied to a blockage

Enforcement steps vary by city, from a notice of violation to fines or more frequent inspection.

What does TCEQ require when the trap is pumped?

A registered hauler, a full pump-out and a signed trip ticket. Under RG-389, only sludge transporters registered with TCEQ may pump and haul grease trap waste, under 30 TAC Chapter 312, Subchapter G. Ask to see the hauler's Notice of Registration and check for an unexpired sticker on the truck door.

The trap must be fully evacuated within 24 hours of the transporter arriving for a scheduled service, even if that takes more than one truck, under 30 TAC §312.143(c).

The generator stays responsible until the waste reaches an authorized facility. Check that the trip ticket shows your name, the waste type, the trap capacity, the volume collected and the date and time. Then make sure you get the final copy signed by you, the hauler and the receiving facility. Ask your local authority how long to keep these records.

Used fryer oil that never passes through a trap, called yellow grease, is different. RG-389 says the Texas Department of State Health Services, not TCEQ, regulates its transport, and it is stored in a separate container for the recycler.

How often does a grease trap need pumping?

As often as its size, your grease load, the manufacturer and the local ordinance require. RG-389 lists those factors and advises pumping before the trap is full. Your city's FOG ordinance may set its own interval, so check it.

An interceptor that is hard to reach tends to get pumped less often than the schedule says. Access belongs in the design.

Who does FOG compliance apply to?

Almost any food service kitchen on a sanitary sewer. That includes new restaurants, tenant improvements, shared kitchens and food halls, grocery prepared food areas, commissaries, cafeterias and hotels. For chains and franchises rolling out many sites, each city's ordinance can differ.

A tenant improvement has to work with the building's existing interceptor, or add one if the existing unit was not sized for the new kitchen. In a shared kitchen or food hall, several operators may discharge to one interceptor, so it has to be sized for the combined load.

Who is responsible, the landlord or the tenant?

The lease decides, and it should say so plainly. Spell out who maintains and pumps the interceptor serving each space, and who owns the building plumbing and any shared interceptor.

A lease that does not assign these duties can leave a landlord exposed to a tenant's violations. That is most likely in a multi-tenant building where the utility finds the problem at the shared sewer connection and cannot tell which kitchen caused it.

What should be settled before construction starts?

Interceptor size, fixture routing and access, decided with the architect and plumbing designer. Size against the actual kitchen program, not square footage. Two kitchens with the same footprint can produce very different grease loads.

Confirm which sinks, dishwashers and floor drains route through the interceptor, and keep non-grease drains out of it so they do not add flow. On a new pad site, coordinate the interceptor location with the site utility plan, as part of drive-thru and multi-site design.

A quick readiness check before the kitchen drawings are final:

1. Have you read the local FOG ordinance and plumbing code that apply?
2. Is the interceptor sized from the actual fixture list and menu?
3. Does every grease-producing fixture route through it, and nothing else?
4. Can a pump truck reach it easily?
5. Is a TCEQ-registered hauler lined up before opening?
6. Does the lease assign pumping, records and repairs?

If any answer is no, fix it on paper now, while it is a drawing change and not a change order after buildout.

Limits of this article. This is general education. Sizing formulas, pumping intervals, inspection rules and record retention come from your city's ordinance and plumbing code, so confirm them with your utility.

Frequently asked questions

Does my Texas restaurant need a grease interceptor?

Almost certainly, if it prepares or cooks food and discharges to a sanitary sewer in an area with a plumbing code. Your utility's FOG ordinance sets the exact requirement and sizing, so confirm during design.

How is grease interceptor size determined?

From the fixture count, fixture types and expected flow, using the formula in the local plumbing code or FOG ordinance. Run it against your actual equipment plan, not an estimate from square footage.

Can I pump my own grease trap?

Not unless you are a TCEQ-registered sludge transporter. Only registered transporters may pump and haul grease trap waste to an authorized facility.

I'm opening a franchise restaurant in a strip center in North Texas, and the landlord says the existing grease trap is fine. What should I check before signing the lease?

Ask for the trap's size and recent pump-out records, and check that size against your fixture list under the city's ordinance. Then confirm which fixtures route through it and what the lease says about who pumps and repairs it.

I manage a food hall in Texas where six vendors share one interceptor. How do we keep FOG compliance from becoming a building-wide violation?

Size and verify the interceptor for the combined load, set one pumping schedule with a registered hauler, and keep the trip tickets centrally. Put each vendor's kitchen practices and pumping duties in the leases.

Related resources

• Texas Wastewater Pretreatment Permits: What Industrial Facilities Discharging to a POTW Must Know
• Enforcement Response Plans: How Texas POTWs Escalate Pretreatment Violations
• What Utilities and Permits Does a New Drive-Thru Coffee Site Need?
• Sanitary Sewer Overflow Risk in Dallas's Older Watersheds

Opening a kitchen and not sure what the FOG program will ask for?

We size the interceptor, route the kitchen plumbing and check both against the city's ordinance while the drawings can still change.

Talk to an engineer about your kitchen

We specialize in:

• Grease interceptor sizing and FOG pretreatment design
• Kitchen plumbing and interceptor coordination
• Local FOG ordinance review and utility approval support
• Shared kitchen and multi-tenant interceptor capacity checks
• Site utility design for restaurant and drive-thru pads
• Sanitary sewer connection design

Modern Engineering Solutions, McKinney, Texas. Contact: (214) 833-6748 or mod-eng.com