Regulatory compliance manager; fancy title or job description?

Recent activities I have been involved in have made me think that people really don't understand what it is that I do for a living.

There's no secret that I work for a grease interceptor manufacturer, But, what do I do for Schier?

Am I in sales?  No.

Wait, let me correct that.  I believe everyone is a sales person in one way or another.  For example, my wife would say that she is absolutely not cut out to be in sales.  But when she really wants something, she seems to have no problem presenting me with all of the features and benefits that would justify her request - which usually boil down to me having a happy and contented wife.

Hey, who doesn't want a happy and contented wife?

I generally find that preferable to just about anything else in the entire universe as it tends to provide a much "safer" environment at home.

My kids are some of the best sales people I know, with their mom and dad anyway.  They can be very creative in their justifications for why we should do this thing, or buy that thing, or go to such and such a place, all the while hammering home the features of this or that and the benefits that either they specifically would enjoy or that we all would collectively enjoy together.

Sales is really just the art of persuasion.  Some are naturally more gifted at it than others', and they typically end up selling for a living, but everyone has sold someone something at some point in their life.

Okay, so in the sense of doing "sales" for a living, no, I don't do that anymore. In other words, Schier does not pay me to sell anything.  I can't even tell you what our sales look like anymore because I am very much out of that loop.

So what do I do?

You might say that I am an advocate.

Merriam-Webster's dictionary defines advocate as, "one that defends or maintains a cause or proposal", or "one that supports or promotes the interests of another."

Who or what do I advocate for?

I am an advocate for fats, oils and grease (FOG) abatement in wastewater collection systems to reduce or eliminate sanitary sewer overflows (SSO) and their resultant risks to human health and safety.

That is my job description.  It has taken a while for it to come into clear focus, even for me.

What it means is that, while I am paid to do what I do by Schier Products, I am not paid to promote or sell for Schier Products.

I am in fact paid by Schier Products to advocate for what I think is right for FOG abatement in wastewater collection systems.

The advocacy I do is both internal and external to Schier.

When working with Schier I may advocate for some specific product improvements to make field inspections by pretreatment personnel easier or I might advocate for a new product to solve problems I am seeing in the field.

When working with pretreatment programs I may advocate for improving the requirements in an ordinance, or to remove some restrictive language that will hurt enforcement efforts, or to stop mandating products that are untested for performance.

When working with plumbing codes I may advocate for improved less-confusing-language regarding which fixtures should be routed to an interceptor, or I might take a stand against proposed changes that might lead to conflicts with pretreatment requirements or would loosen restrictions that would, in my opinion, be harmful to wastewater collection systems.

When working with standards such as ASME A112.14.3, I might advocate for more accountability in the standard and less prescriptive design requirements that shackle manufacturers and stifle innovation - something very much needed in grease interceptor design and operation, in my opinion.

I think it's important to understand that I see what I do, not as a job, but as a calling.

I believe in the "cause" of FOG abatement.

When you passionately believe in something you are willing to fight for it. You are willing to take actions that you believe in your heart will make a difference for your cause.

I guess that means that you might ruffle a few feathers. You might not "go along" to get along - if getting along means compromising what you believe in.

That being said, I love engaging with the pretreatment community and others who are equally interested in the issues surrounding FOG deposit formation and the exploration of solutions that might mitigate its deleterious effects.

My job title sure can be confusing, but I take my role in the cause seriously and I welcome the challenges, debates, and struggles that are necessary to make a real difference for us all.

Are Automatic Grease Removal Devices the Answer?

I regularly get asked to talk about Automatic Grease Removal Devices (AGRD), you know, the pro's and con's.

I fully realize that blogging about this topic is risky.

By risky, of course, I mean like when a woman says, "does this dress make me look fat?" and you are stupid enough to say, "it's not the dress!"

It may be true, but that won't save your life.

It doesn't matter what the AGRD looks like or how it works, the underlying concept is flawed.

Okay, before you hit the send button on that you-should-die-a-horrible-death-because-you-suck-you-ignorant-jerk email, let me explain.

The devices are not flawed - its the concept behind them that is flawed.

I don't have reason to doubt manufacturer's claims of performance, because many of them have been tested to ASME A112.14.3 and A112.14.4.

So what is the flawed concept behind them?

While specific design elements vary by manufacturer there are several general design elements that most AGRDs share.

• Heating element - most manufacturer's require a heating element that keeps the contents of the AGRD liquified, which makes transporting the FOG easier.
• Motorized skimming device - a means of removing the accumulating FOG from the AGRD.
• Attached exterior collection container - where the accumulated FOG is deposited by the skimming device.

Nearly all manufacturer's instruct the restaurant to maintain their interceptor on a daily basis.  As the collection container fills with FOG it must be emptied.

The nature of the collection container being attached to the side of the unit requires it to be readily accessible for removal and replacement.  Normally this restricts the installation of these devices to above the floor where they are limited to the number of fixtures that can be effectively routed to them.  That is why they are usually sold as a point-source interceptor.

Okay so here's the conceptual flaw - restaurants do not discharge 100% of there FOG through just one fixture in the kitchen, i.e. three-compartment sink. 

Yes, I have heard the argument that 90% of the grease in a commercial kitchen is handled through the multi-compartment sink.

No, I have not seen any credible independent studies that conclusively prove this hypothesis. In fact the most experienced FOG inspectors in the industry dispute this claim with passion.

Also, I have been in actual kitchens in the field, you know, where real people are busy cooking and cleaning.  I've seen the grease that runs down the front of the fryers, and the greasy spills on the kitchen floors.  I've noticed the grease build-up on the walls.  I've seen kitchen staff scraping food scraps from dishware into the food grinder sink, that isn't routed to a grease interceptor.  I've seen people dump residual soup down the hand sink because it was the closest fixture.

There is a very basic scientific principle which explains this phenomena.

Harvard Law states, "under the most rigorously controlled conditions of pressure, temperature, volume, humidity, and other variables, an organism will do as it damn well pleases."

That pretty much describes a working commercial kitchen.

The only assurance that a restaurant won't discharge FOG to the collection system is to route all fixtures in the kitchen to a properly sized, installed and maintained grease interceptor.  By all fixtures of course I mean ALL FIXTURES.  Floor drains, floor sinks, three-compartment sinks, vegetable sinks, prep sinks, food grinders, dishwashers, mop sinks, woks, soup kettles, trench drain, bar sinks and even washing machines.

If the fixture is in the kitchen or bar area it needs to be routed to a grease interceptor.

It is possible to install an AGRD inside of a vault so that more fixtures can be routed to it, but then you have to make sure the device is certified to handle the extra flow rate; not all are.

Also, once the device is buried in a vault, the vault must remain unobstructed so that it may be opened at anytime by staff to maintain the collection container.

There is one other teeny, weeny, itsy, bitsy little problem to consider.

Odor.

One of the most common complaints regarding AGRDs is odor.  Apparently heating up the contents to keep the FOG liquified also enhances its pungent smell - creating a kitchen atmosphere of loathing and disdain for the device creating the odor. 

The universal solution to this problem appears to be to unplug it.  Jurisdictions across the country report finding AGRDs unplugged in local restaurants.  When asked why the device is unplugged, kitchen staff invariably cite the raunchy odor.

You don't have to believe me, feel free to go into any kitchen that has one of these devices installed and smell for yourself.  That is if the thing is plugged in.

If it is not plugged in, feel free to plug it in for them while pointing out, "hey you know this is supposed to be plugged in to work properly, right?!"

Then run.

Does this mean that there isn't any good application for an AGRD?

Nope.

In fact I am a believer in their application for rotisserie chicken oven's, for example.  These ovens can crank out hundreds of pounds of liquified chicken fat in a week - way too much volume for a typical passive grease interceptor. 

There are probably many other industrial cooking applications that these devices would be perfect for.

But, as a primary grease interceptor for a restaurant receiving the discharge from all the fixtures in the kitchen, I'm dubious to say the least.