Section 111 Water Industry Act 1991: What It Means & How to Avoid Fines
Have you received a letter from your local water company stating you need to take action due to blockages in the sewer system that have been linked to your business? Whether you have and are worried about the next steps, which could include fines or enforcement, or you just need more information on how to handle things if this situation arises, Aqua Mundus is here to help.
Under Section 111 of the Water Industry Act 1991, it is illegal to discharge substances that can damage or block the public sewers, with fats, oils and grease (FOG) being a common harmful substance that commercial hot food service businesses deal with daily.
Your business must follow these FOG regulations and we’re here to explain in this guide, what Section 111 means, why your business might receive a letter from your local water authority, how to become compliant and why the right grease trap is the perfect solution you need.
What Is Section 111 of the Water Industry Act 1991?
The Water Industry Act 1991, Section 111 outlines the requirements people must follow concerning harmful substances entering their drains that connect with the public sewer.
Section 111 of the water industry act 1991 classes several harmful substances, including:
- FOG – fats, oils and grease produced from cooking
- Food waste – scraps of food not scraped into the bin
- Chemicals – any chemical refuse, petroleum spirit, carbide of calcium or any liquid of a temperature higher than 43°C.
These substances can make their way into the sewers and cause serious damage to the public sewer system, the environment and public health when commercial businesses don’t follow UK regulations and have systems in place that can prevent harm.
Who Enforces Section 111?
Water companies, like Severn Trent and Thames Water, and in some cases other local authorities enforce Section 111 of the Water Industry Act 1991.
These authorities monitor sewer systems and investigate issues such as blockages or damage, and will investigate to uncover the root cause, which could be a commercial business allowing harmful substances to enter drains.
Why Have You Received a Section 111 Letter?
If you have received a Section 111 letter from your local water authority, fortunately it doesn’t mean the worst-case scenario you might think.
Your business could receive a Section 111 letter if a water company has discovered your premises have failed to follow UK FOG and wastewater regulations. The most common reason you’ll receive a letter is because FOG produced in your premises has caused blockages, pollution or damage to the sewer system.
FOG will have caused damage due to poor maintenance or a complete lack of a grease trap. Receiving a Section 111 letter doesn’t mean you will automatically be fined, it’s more of a formal notice where you must take immediate action.
What Happens If You Ignore a Section 111 Notice?
Upon receiving a Section 111 notice, your business must cease to operate immediately and work with whoever is enforcing the notice and take remedial action.
Failure to take action will result in fines and potential prosecution. The fines will depend on the severity of the offense, but you can face substantial penalties, especially in cases involving environmental harm or repeated damage.
Additionally, if you fail to comply with the notice, the water authority has the power to take legal action against you. This may result in prosecution in a magistrates’ court.
If you do not carry out the required work by working with a third-party contractor within the specified timeframe, the water company can step in and complete the necessary repairs or corrections themselves. You will then be billed for the full cost of the work, which may be significantly higher than if you had arranged it independently.
In some cases, your actions or inaction could cause damage to neighbouring properties or public infrastructure. This could expose you to civil claims for compensation, adding to the financial burden. Failure to act on sewer issues can also affect your property’s condition and may complicate insurance claims, where insurers can refuse to cover damage because you’ve failed to comply with Section 111 notices.
How Grease Traps Help You Stay Compliant
With FOG being the main cause for hot food businesses to receive an enforcement notice, your premises require the right systems to stop them entering the sewer system. Enter the grease trap, also called a grease interceptor.
Grease traps reduce the risk of FOG blockages by separating fats, oils and grease from wastewater, and have a licensed waste collector come and remove the accumulated grease on a scheduled basis.
Installing a grease trap will help you meet water authority requirements, including Section 111 of the Water Industry Act 1991, avoid fines and enforcement.
NOTE: Disclaimer
Whilst every effort has been made to ensure the accuracy of the information supplied herein, Aqua Mundus Limited cannot be held responsible for any errors or omissions and the contents should not be taken to constitute legal advice.
Talk To An Expert
Whatever your grease management needs, put us to the test and you won’t be left disappointed. Thousands of clients already rely on the experience and expertise of Aqua Mundus, so get in touch to see how we can help you.
Grease Trap Solutions for Section 111 Compliance
Grease trap installation needs to consider the correct sizing for the amount of FOG produced and your wastewater flow rates. Undersized traps will quickly become overwhelmed, allowing FOG to pass into the drainage system, while oversized units may lead to inefficiencies and unnecessary costs. Proper sizing typically considers factors like the number of sinks, dishwashers, peak service times and the type of food prepared.
A well-designed grease trap system ensures smooth flow and efficient separation of grease from wastewater. This includes proper pipe gradients, ventilation and flow control to allow enough time for FOG to separate and rise to the surface. In larger or high-demand environments, multiple traps or a combination of passive and automatic systems may be required.
Ongoing maintenance is essential to keep the system functioning effectively and to demonstrate your compliance if inspected.
Performing routine checks help identify early signs of issues such as excessive grease build-up, blockages or structural wear, or things that mean you have failed to comply with grease trap compliance or the Water Industry Act 1991. Schedule inspections based on usage levels. A good rule of thumb for high-output kitchens is to inspect grease traps weekly, while smaller kitchens can inspect systems every one to three months.
You should also monitor how well the trap is separating grease from wastewater. If FOG levels in the outflow begin to rise, it may indicate the system is overloaded, incorrectly sized or not being maintained properly. Always keep maintenance logs for evidence of due diligence in the event of enforcement action.
Grease trap cleaning is one of the most important aspects of grease trap management, and helps you comply with Section 111 and other UK environmental regulations.
Over time, FOG accumulates and reduces the trap’s capacity. Regular removal ensures the system continues to function effectively. If left too long, hardened grease can cause blockages, unpleasant odours and eventual system failure.
Extracted waste must be disposed of in accordance with environmental regulations. This typically involves a licensed waste carrier who can transport and process the waste safely. Improper cleaning and waste disposal can lead to further legal issues, even if the grease trap itself is working correctly.
Even well-maintained grease traps can develop faults over time, and prompt repairs are essential to avoid breaches. Issues such as leaks, slow drainage or ineffective separation should be addressed immediately. Delaying grease trap repairs increases the likelihood of FOG entering the sewer system, which can trigger enforcement action.
Components like baffles, lids, seals and internal filters can wear out or become damaged. Replacing these parts promptly ensures the system continues to operate. Sometimes, updating outdated equipment may be more cost-effective than repeated repairs.
Are Grease Traps a Legal Requirement?
Grease traps are not always explicitly required by law in every situation. However, this doesn’t mean UK businesses can ignore FOG regulations.
Under the Water Industry Act 1991, it is an offense to discharge substances that can obstruct or damage the public sewer system, including fats, oils and grease. Businesses, particularly in the food and hospitality sector, have a legal responsibility to ensure their waste water does not cause blockages or pollution.
While the law may not always state that you must install a grease trap, they are the most widely accepted and effective method of compliance and are the safest way to avoid costly penalties.
Talk To An Expert
Whatever your grease management needs, put us to the test and you won’t be left disappointed. Thousands of clients already rely on the experience and expertise of Aqua Mundus, so get in touch to see how we can help you.
Signs Your Business May Be Non-Compliant
Let’s break down some of the key signs your business may not be compliant with wastewater regulations for commercial kitchens, more specifically Section 111 of the Water Industry Act 1991.
Frequent blockages are one of the clearest warning signs of poor FOG management. If your sinks or drainage systems regularly back up, it often indicates a build-up of grease and food waste within the pipework. Left unresolved, this can lead to sewer misuse and potential financial and legal action.
Persistent unpleasant odours coming from sinks, drains or external pipework can signal decomposing grease deposits. These smells are not just a hygiene concern; they often point to underlying issues with grease accumulation that could put your business at risk of non-compliance.
Visible grease in pipes, inspection chambers or manholes is a strong indicator that FOG is not being properly captured or managed. This suggests that either no grease control system is in place or that an existing system is failing or poorly maintained.
If water drains slowly from sinks or kitchen equipment, it’s likely due to grease narrowing the internal diameter of your pipes. Over time, this restriction worsens, increasing the risk of full blockages and non-compliant discharge into the sewer system.
Operating a commercial kitchen without any form of grease control system significantly increases the risk of FOG entering the public sewer. While not always explicitly mandated, the absence of a grease trap or equivalent solution, like biological grease dosing systems, makes it much harder to meet your legal obligations.
How to Avoid Section 111 Fines
Stick to these key actions to avoid fines for breaching the Water Industry Act 1991 Section 111 regulations:
- Install and regularly clean a grease trap
- Maintain your system and keep records for audits and inspections
- Use licensed waste disposal for your accumulated waste
- Schedule inspections from a professional service provider
How Aqua Mundus Can Help
Aqua Mundus is here as your compliance partner and full service provider to help you manage FOG, keeping you compliant with Section 111 of the Water Industry Act 1991 and other legal requirements. We can provide turnkey services, including the design and installation of grease traps, perfectly suited to your commercial kitchen. We also keep systems compliant and running properly with servicing, cleaning services and repairs, with emergency support available.
Book a compliance assessment with our expert team and gain ultimate peace of mind your business adheres to all relevant regulations to avoid fines and prosecution.
Talk To An Expert
Whatever your grease management needs, put us to the test and you won’t be left disappointed. Thousands of clients already rely on the experience and expertise of Aqua Mundus, so get in touch to see how we can help you.
Section 111 Water Industry Act FAQs
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Who enforces the Section 111 Water Industry Act?
Section 111 of the Water Industry Act 1991 is enforced by local water and sewerage companies. They monitor discharges into public sewers and can issue notices, fines or legal action against businesses responsible for misuse or blockages.
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What is the Water Industry Act 1991?
The Water Industry Act 1991 is UK legislation regulating water supply and wastewater services. It sets out responsibilities for businesses and individuals, including preventing harmful discharges into public sewer systems.
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How often do you need to clean a grease trap?
Cleaning frequency depends on usage, but most commercial kitchens require grease trap cleaning every one to three months. High-volume operations may need more frequent servicing to prevent overflow, blockages and compliance issues.
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What size grease trap do I need?
The correct grease trap size depends on kitchen output, number of sinks and wastewater flow. Our professionals at Aqua Mundus can assess your premises and match the ideal system to handle peak demand without allowing grease into drains.
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What is a grease trap & how does it work?
A grease trap is a plumbing device that captures fats, oils and grease from wastewater. It slows water flow, allowing FOG to separate, float and be contained before entering the sewer system.
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How to dispose of grease trap waste?
Grease trap waste must be removed by licensed waste carriers and disposed of at approved facilities. This ensures compliance with environmental regulations and prevents illegal dumping or contamination of land and water systems.
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How to unclog a grease trap?
To unclog a grease trap, remove accumulated grease and debris, clean internal components and flush the system. Severe blockages may require professional servicing to restore proper flow and prevent further problems.
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How much is a grease trap?
The cost of a grease trap will vary depending on size, type and installation complexity. Small units may cost a few hundred pounds, while commercial systems with installation can run into several thousand.
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What are the signs that my grease trap is full?
Common signs include slow drainage, foul odours, visible grease build-up and frequent blockages.
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Are grease traps a legal requirement?
Grease traps are not always legally required, but businesses must prevent fats, oils and grease entering sewers. Grease traps are seen as the most effective way to ensure compliance.