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Tote reference

Used, as-is IBC totes: what the grade means

A used, as-is tote is emptied by ordinary pumping or draining, with an intact bottle, valve and cage. It has not been washed, so residue of the last contents is still inside.

Form condition
used
Washed
No
Bottle, valve, cage
Intact
Decided by
Last contents

The honest middle of the scale

Most used totes arrive here. Nothing is wrong with them; nothing has been done to them either. The buyer either cleans the tote or fills it again with the same product.

When it works

A tote that held a product and goes back to the same product needs no wash. A neighbouring supplier with the same product is the natural buyer. The request should say what the tote held, to the word.

The limit

Used, as-is is not RCRA empty by default. The tote is empty only when the heel is an inch or less, or 0.3% of capacity by weight. Run the Empty Check first.

Why “used” is the honest label

The form’s value for this grade is simply “used”. It describes a tote that was emptied the ordinary way, still has all its parts and was put aside. Most totes on a loading dock look like this. They are not spotless, and they are not damaged.

The label is blunt because it avoids implying work that was not done. A tote that has been through nothing but pumping is not reconditioned, rinsed or rebottled, and the grade says so.

Reuse for the same product

The best home for an as-is tote is a user of the same product. A producer that buys a syrup in totes can take back a syrup tote with a film of the same syrup in it. The residue is not a contaminant for that user.

A different product is another matter. A film of one product in a tote that will hold another can ruin a batch. The buyer cleans, or the tote goes to another grade.

What to include in a request

  • The product and supplier as printed on the label.
  • How the tote was emptied.
  • The heel, measured.
  • Whether the label and plate are legible.

A warning about mixing products

A used, as-is tote moved to a different product can contaminate it. Even a small film of a surfactant can foam a batch, and a trace of a solvent can ruin a food product. The buyer for this grade should know the previous product by name.

Questions people ask

Is an as-is tote legally empty?

Not automatically. It is empty under 40 CFR 261.7 only if the heel is an inch or less or 0.3% of capacity by weight, after pumping or draining.

Can an as-is tote be washed later?

Yes. A washed tote moves toward rinsed or reconditioned, depending on whether it is also tested and certified.

What if I do not know the last product?

Say so. A tote with an unknown past is recycled; it cannot go to reuse.

Is as-is the same as unwashed?

Yes. The tote has not been washed, so some residue of the last contents remains.

Keep reading

Sources

Last reviewed . General guidance, not legal advice.