Problem
Currently there are approx. 500,000 FSE kitchens in the UK which discharge wastewater to the public sewer network, this includes approx. 55,000 takeaway only kitchens. All wastewater from FSE’s is currently considered ‘domestic in nature’ as it is considered similar to household kitchen sink & dishwasher discharges, however the loading/concentration of FOG & Foodwaste in FSE discharges is far greater than the domestic levels.
Although there have been fish and chip shops since the 19th century, due to societal shifts there has been a significant increase in FSEs, particularly in urban areas. The largest increase has not been in what could be considered as traditional restaurants, but in smaller establishments, typically fast food and/or takeaways.
Most fast-food outlets have been established in vacated shop premises as the function of a town or city centre has changed from shopping to a social and cultural ‘centre’ where friends and family meet to eat & drink.
Consumption of food at these establishments is different to traditional restaurants as often there is no space for consumption on-site or there is no crockery or cutlery (e.g., McDonalds) but floors, surfaces and equipment are still washed down, and the wastewater goes to sewer. This means that sinks, dishwashing, and ware-washing equipment in the kitchens are used as they produce a reduced volume of wastewater, but with a higher grease intensity.
In addition, traditional restaurants, and the newer trend of ‘dark or ‘ghost’ kitchens (those that provide take-out food with no retail service on the premises and operated by platforms such as Uber Eats, Just Eat & Deliveroo), also contribute to the operational risk of sewerage wholesalers.
In the UK, Document H1, section 2.21 of Building Regulations states any commercial premises that is serving food and is connected to the mains drainage system ‘should’ be fitted with a grease trap or separator. When build costs rise and savings need to be made, the ‘should’ will always be dropped.
Impact
Southern Water has 28,000 FSE’s (commercial kitchens) in its area – Southern Water data presents that circa 60-70% of blockages have some FOG content…… with 15% of our annual blockage number (20,000) being purely FOG. All Water and Sewerage Companies (WaSC’s) have similar figures.
The impact of FSE FOG to the sewer system was highlighted during lockdown for Covid19 – wastewater treatment works (WTWs) reported a huge drop in FOG on inlet screens despite the domestic level of ‘background FOG’ still being there or in fact raised. Thus, proving the FSE FOG volume and content in their wastewater is the substantive cause of the ‘Fatbergs’ we are seeing, and having a massive impact on businesses, their customers, and their neighbours – not to mention the costs involved and the threat to the environment.
The environment is impacted significantly because of odours, blockages, floods, CSO use, and pollution attributable to FOG discharges to the public sewer.
The principle that the ‘producer pays’ for correct disposal of any waste is supported by the Environment Agency, and suitable FSE charging tariffs would align with this ethos in the Water Industry. Currently all household customers (and other commercial customers) are being charged to cover increased discharge costs relating to FSEs. The incentive for the FSE owner/operator would be risk-based charging to promote behaviour change.
The Water Act 2014 – Sections 16 & 143 (A though E) has not addressed the control of discharges or any behaviour changing or variable tariffs. Customer charging is considered the leading approach in the absence of robust ‘regulatory or legislative’ methods of ensuring all FSE’s fit some grease management to prevent FOG discharge. Financial incentive places the responsibility on the FSE owner/operator to respond and change their behaviour/installations or pay higher risk-based charges.
Project
The implementation of FSE tariffs following this project is likely to result in the end user (FSE owner/operators) demanding commercial innovation and invention to provide more efficient and effective grease management systems to lower their wastewater charges and collect the maximum amount of FOG, which would in turn feed the circular economy as detailed in the Defra ‘Plan for Water’. This in turn could produce carbon credits for the producer, collector, and user of the FOG – which would support Net Zero challenges.
Currently the grease management industry is unregulated, but this project would help drive an improvement in honest disclosure of the efficiency of grease management equipment to the end users. This would be additionally supported by new standards that are being written for testing grease management at BSi – PAS 409 & 406.
These charging changes will also lead to the overall reduction of FOG discharged to sewer, thus reducing the sewerage wholesaler risk of odours, blockages, floods, and pollution.
Project Outputs
- Project report summarising the findings – with executive summary of recommendations.
- Engagement and dissemination event for the UK and Northern Ireland Water Sector.
- Effective, innovative, and efficient grease management installed in all FSE’s
- Recommendations and risk-based charging included in PR24 business case
- Effective risk-based charging supported by Ofwat for AMP8
- Support for the growing circular economy
- Support for a regulated grease management industry