(e) Fats, oils, and greases (FOG) means organic polar compounds derived from animal and/or
plant sources that contain multiple carbon chain triglyceride molecules. These substances
are detectable and measurable using analytical test procedures established in 40 CFR 136,
as may be amended from time to time. All are sometimes referred to herein as "grease" or
The kicker is this line here: These substances are detectable and measurable using analytical test procedures established in 40 CFR 136, as may be amended from time to time.
Mostly you should be interested in 40 CFR 136. God bless the Feds and their online publications. 40 CFR 136 is in reference to:
So your going to have to dive a little deeper and look into section 136.3 Identification of test procedures to find your pollutant. As far as I know coffee isn't listed. So your only avenue left is to contact the EPA directly.
If you can convince the Feds that coffee is practically harmless you will forever be known in the coffee world. But in all honesty the EPA needs find out how much grease coffee and espresso releases as waste. My best guess would be not very much and you would fall under any minimums.
But I don't foresee this working to your advantage and you will most likely find it easier to purchase the smallest system you can buy.
I've pretty much heard the same. I have only met one person who truly found a way around a grease trap. Any drinks made wrong were thrown away in a garbage can. I guess she convinced the local heads that she wasn't going to produce enough grease to fill a gallon container in a year. The only item she had to wash was the steaming pitcher.
She did pretty well at first but ended up closing shop because rent at the local mall for her kiosk was killing her.
As for the argument above, it would make sense to go down that road. I have heard numerous inspectors use coffee as a grease source even if it produces very small amounts. It would be nice to see a ruling that you could lean on. Yes you do or no you don't.
Believe it or not you most likely can file a grievance if you don't think you can afford a grease trap for your kiosk. Funny thing those grievances are. A retail chain not to far from me did just that when they were building out. They were supposed to install a $20,000 system so they would meet code.
But they filed a grievance and said they couldn't afford it and were awarded it. So now they have a very very small system and have to have it pumped out every week or two. What really gets me is they dumped more then 1/2 million into their shop and they had the backing of a big corporation in Iowa.
But you know how cities work, keep the big guy happy and screw everybody else.
Here is a site to check out about coffee franchises. www.coffeefranchisereviews.com. Its a fun site with some great new concepts. Lots of free information about how to open a coffee shop. Check it out.