What happens during a Phoenix commercial grease (FOG) inspection?

The FOG manual describes the visit in order. The Environmental Services Division's commercial inspectors educate and inspect commercial facilities to enforce city code and the Clean Water Act. "Commercial inspections are unannounced," and inspectors "try to come in off hours to have as little impact on the business as possible." They are in uniform, carry City of Phoenix identification and drive a City vehicle.

On arrival the inspector shows identification, explains the purpose and tells the manager or owner about their rights. You may accompany the inspector except during confidential interviews, you can get copies of any original documents taken and of any analysis of samples, you can ask for a split or duplicate of any sample where that would not prevent the city from analyzing it, and each person interviewed is told their statements may go in the inspection report. The manual says the section "rarely takes samples," does not take original documents and does not tape record interviews. An appeal of a final city decision based on an inspection may be brought under the appeal provisions of the Phoenix City Code or by a special action in Maricopa County Superior Court.

The inspector will want to see four things:

• Maintenance records. They show how often the interceptor is cleaned. City code requires them on site for three years.
• The interceptor. The inspector checks for missing parts or a rotted-out unit, and how much grease is inside, to judge whether the pumping schedule is enough.
• The kitchen. The inspector counts the grease-bearing fixtures, meaning sinks, floor sinks, floor drains, garbage disposals, mop sinks and dishwashers, to decide whether the current interceptor is properly sized.
• Outside. The tallow bin and trash area must be clean, with no cooking oil or garbage on the ground and dumpsters closed when not in use. Oil and debris on the ground wash into the storm drain in the rain, which the manual calls a violation of Phoenix City Code Chapter 32C.

The inspector reviews the findings with ownership or management. If something needs correcting, such as a cleaning, a broken or missing part or a replacement, the inspector issues a requirement and prescribes a time frame. The time frame is based on the impact on the sewer system and how much work the fix takes. Extensions "can be granted based on business needs if the request is in writing." An extension does not stop the city from enforcing if a sewer blockage or another Chapter 28 violation happens in the meantime.

• FSE: food service establishment.
• Grease-bearing fixture: any kitchen fixture that sends grease-laden water toward the interceptor. Hand sinks do not count.
• Requirement: the order the inspector issues to clean, repair, replace or otherwise fix a problem, with a time frame to finish.

Every food service establishment in the City of Phoenix that discharges to the city sewer, and the property owner where several tenants share an interceptor.

• An inspector arrives with no warning shortly after closing time. The manual says routine inspections are unannounced and inspectors try to come in off hours. The manager can accompany the inspector and should be able to pull the records folder in minutes.
• The records are at the owner's office across town. The code puts the records on site, so the visit ends with a documentation problem that a folder in the kitchen would have avoided.
• The inspector counts six fixtures and a dishwasher against a small trap. The count is the check for whether the interceptor is properly sized. The manual limits hydromechanical traps to kitchens with four or fewer plumbing fixtures and no dishwasher or garbage disposal, so this kitchen needs a gravity interceptor.
• A restaurant needs more time to replace a rotted interceptor. It asks in writing. The extension can be granted, but a sewer blockage in the meantime still allows enforcement.

1. 1Keep a records folder at the restaurant with three years of pumping invoices.
2. 2Count your grease-bearing fixtures and compare the count to the interceptor size.
3. 3Look at the interceptor at the next pump-out, and check that no parts are missing.
4. 4Keep the tallow bin and dumpster area clean and the lids closed.
5. 5If a requirement arrives, note the time frame. Ask for more time in writing before it passes. The Environmental Services Division gives 602-495-0278 as its appointment line for interceptor plan review.

• "Inspections are scheduled." The manual says they are unannounced.
• "Only the interceptor matters." The inspector also reviews records, fixtures and the outside area.
• "An extension pauses enforcement." The manual says the city can still enforce if a blockage or violation occurs.