Property Types

Grease Trap Servicing & Recycling

Grease traps, or interceptors, are often located at restaurants, cafeterias, and other food service businesses. Grease traps contain waste fats, oils, and greases (FOG) that must be pumped out as part of a regular maintenance program to keep them in good working order. Collected wastes must be properly recycled or disposed of at rendering plants, wastewater treatment plants, recycling facilities, or other facilities. Some recycling facilities solidify the waste and then sell it to agriculture for use as a fertilizer on fields or as compost. Other facilities separate the brown grease from water to produce biodiesel fuel and process wastewater to produce methane gas or boiler fuel. Businesses that recycle grease trap waste, service grease traps, or collect and transport the waste can face various environmental risks. FOG accidents or leaks while servicing grease traps, treating FOG, or transporting, loading, unloading, treating, or storing wastes can result in cleanup liability and impact third parties or natural resources. Additional pollution exposures could result from products produced, wastes, or emissions generated through recycling or improper maintenance of trap systems if servicing them.

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Environmental Exposures May Include

FOG Contamination
Loading & Unloading
Chemical Storage
Waste Management
Sewer Overflows
Wastewater
Stormwater
Air Emissions
Flammables
Waste Product

FOG Contamination

During servicing, companies pump out waste liquids and solids from grease traps. If spills or leaks occur during servicing, FOG, bacteria, and other debris can migrate to storm sewers, drywells, surface water bodies, or adjacent properties. Impacts on aquatic life, natural resource damages, contamination of drinking water sources, or property damage can result.

Loading & Unloading

Spills or leaks of grease trap wastes can occur during loading or unloading operations or transport due to vehicle upset, overturn, or equipment malfunction, resulting in environmental impacts, third-party bodily injury or property damage, or natural resource damages.

Chemical Storage

Grease trap waste recycling companies may store chemicals, wastes, and products on-site in containers and aboveground or underground storage tanks, and they may transfer these materials in piping between parts of their facilities. Leaks or spills from storage containment or piping systems could cause cleanup liability, third-party claims, or natural resource damage claims.

Waste Management

Greasetrap waste recycling facilities may generate waste as part of their operations. Improper handling or disposal of generated wastes could result in cleanup and tort liability.

Sewer Overflows

Maintenance may be performed on grease traps at a customer’s business. If the work performed by a service contractor results in a malfunction of the grease trap system, a sewer system overflow could result in claims for bodily injury, property damage, or environmental impacts.

Wastewater

Wastewater generated from treatment operations or equipment and vehicle cleaning may be contaminated with FOG, bacteria, bleach, detergent, and chemicals. Wastewater treatment systems may be present at facilities, or wastewater may be taken to a non-owned disposal facility or wastewater treatment facility. Releases of insufficiently treated wastewater or spills could occur during cleaning, transport, or transfer from waste storage areas and create environmental risks.

Stormwater

Stormwater coming into contact with waste during storage or handling can contaminate storm drains, surface waters, or nearby third-party properties. Cleanup or tort liability can result.

Air Emissions

Air emissions may be produced at recycling facilities during processing, and malfunctions or issues during processing can lead to permit exceedances. Third-party damage claims or regulatory violations can result.

Flammables

Some of the products produced from processing grease trap wastes are combustible or flammable, which increases the possibility of a fire that could release toxic fumes or smoke. Firefighting water or foam could create contaminated run-off that migrates to nearby properties or storm drains, resulting in environmental cleanup and tort liability.

Waste Product

Bodily injury, property damage, or environmental damage can result from pollution exposures from a recycled grease trap waste product’s use, failure, or defect, resulting in tort liability for the recycling company.

Environmental Pollution Liability Can Provide Coverage For

Integrated GL/site pollution and options to include excess, auto, and work comp may be available for Recyclers.

Monoline site pollution liability

Contractors pollution  liability

Third-party claims for bodily injury and property damage

Third-party claims for cleanup

Defense of third-party claims

First-party emergency response costs

Both sudden and gradual pollution conditions

Mold, legionella, bacteria, and fungi

First and third-party transportation pollution liability

Loading and unloading

Non-owned disposal sites

Natural resource damage

Silt and sedimentation

Aboveground and underground storage tanks

Products pollution liability

Business interruption expenses

Crisis/reputation management

Claims Scenarios & Examples

A truck carrying grease trap wastes overturned on a bridge over a creek. Over 1,000 gallons of used cooking oil and grease were released onto the road and into the creek. Booms were placed in the creek to contain the grease and solids, and a vacuum truck was used to recover the spilled material. The contractor was liable for the cleanup costs for the roadway and creek.
While pumping out a grease trap at a restaurant, the hose connection came loose, spilling the grease trap waste onto the ground and into a nearby storm drain. The wastes flowed into an adjacent stream. The contractor incurred emergency response and long-term monitoring costs for impacts to the stream.
Biodiesel was stored in a large aboveground storage tank at a grease trap waste recycling facility. The tank developed a leak which resulted in the release of 1,000 gallons of biodiesel fuel. An emergency response contractor was contracted to clean up the spill. The facility was liable for the emergency response costs.
Grease trap waste was pumped into a tank at a recycler’s facility. The tank failed, and a stormwater drain in the secondary containment had been left open. Wastewater and solids escaped the secondary containment and flowed onto an adjacent property. The adjacent property owner sued for property damage associated with the release.
A grease trap service contractor was responsible for regular maintenance on a grease trap for a large restaurant. The incoming line to the grease trap clogged due to a foreign object, causing sanitary water to back up into the restaurant, resulting in property damage, food contamination, and business interruption. The restaurant owner sued the contractor, even though his work was not the cause of the backup. The grease trap service contractor’s pollution liability policy defended him against this claim.
A grease waste trap recycling facility produced biodiesel fuel. Approximately 4,000 gallons of biodiesel fuel were released from a corroded underground pipe. The fuel contaminated nearby soil and groundwater and seeped into the adjacent river, creating a visible sheen. The company faces penalties, cleanup cost reimbursement, and natural resource damage assessment costs totaling more than $1 million.
A recycler collected waste cooking oil fats from restaurants and processed it into an animal feed supplement. The fats were contaminated with lasalocid and lascadoil, two chemical agents that can be toxic to animals at higher doses. A customer of the animal feed supplement sued the recycler for delivering a defective product. The recycler’s general liability carrier declined the claim citing a total pollution exclusion in its general liability insurance policy.

Final Consideration

Your business can be faced with the cost to defend itself against allegations or legal action from pollution related events, regardless if you are at fault or not. Having the proper insurance coverage in place will help fund the expenses incurred to investigate or defend against a claim or suit and provide you with environmental claims handling expertise.

Disclaimer

This environmental risk overview offers a general understanding of potential risks and may not reflect all risks associated with your business. Environmental Risk Professionals has compiled this overview for informational purposes only. This overview does not constitute legal opinion or advice, nor does it establish a consultant-client relationship. This overview is not intended to guide project parties in interpreting specific contracts or resolving disputes; such decisions may require consultation with counsel and depend on various factors. © 2025 Environmental Risk Professionals, LLC

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