Overview:
Mick O’Dwyer explores the role that haulers play in a city’s FOG program and looks at how cities can work collaboratively with their haulers, including initiatives like preferred pumper programs, grease cooperatives, and permitting programs.
Key Takeaways:
- Do cities trust their pumpers? Like any industry, there are bad and good players. Trust between provider, city, and FSE is key. Every stakeholder ultimately wants compliance; we need to figure out how to get there.
- Who is responsible vs. accountable?
- FSEs may be accountable to the city and can have enforcements issued against, but they don’t know the specifics of FOG and GCD management.
- Pumpers are regulated at a higher level and can be ignored, but they are, in fact, responsible for the compliance work.
- Expectations of what a pump out actually differs between jurisdictions – some consider it a full evacuation, clean, and refill, others accept skimming.
- There are three types of haulers: Mom + pop; Mid-sized, and National companies (big four). There is a low barrier to entry for haulers, but it’s difficult to retain good staff. In addition, it’s a low-margin business, resulting in shortcuts and difficulty to regulate.
- What haulers want:
- Clear, consistent rules, manifests, and communication
- Enforcement against bad actors
- Easy process, least admin – all haulers struggle with paperwork
- More customers
- Collaborate:
- Perform hauler GCD inspections and check certifications
- Support good behavior, i.e., preferred pumper programs. Example program in Oregon: pumpers must meet certain standards and complete an evaluation to be added to the list. They are evaluated continuously. FSEs can use these to stay in compliance.
- Grease cooperatives: e.g., Tempe Grease Cooperative is a partnership between the city and its FSEs where the city brokers and schedules pump-outs for the FSE.
- Implement consistent regional approaches
- Get to know the business and their people
- Regulate:
- Permit vehicles, e.g., Dallas
- Supervise pump-outs or inspect after a pump-out
- Track manifests and puts a time limit on when manifests must be submitted by