Dirty IBC totes: what the grade means

The heel test

Measure the heel before anything else. If it is above one inch, and above 0.3% of capacity by weight, the tote is not an empty container under the federal rule. The measuring guide shows how.

Where it goes

If the heel can be drained further, drain it and measure again. If the product cures or cannot be washed out, the bottle goes to regrind and the cage to steel. If the tote held a hazardous waste and cannot be drained, it needs a licensed hauler and we take no request for it.

Why not reuse

A dirty tote carries the last product into the next. For any job where that matters, it is not reused.

What counts as a heel above the limit

The federal test is an inch of residue, or 0.3% of the tote’s capacity by weight. On a 275 gallon tote the weight test is 6.9 pounds at water weight, and on a 330 it is 8.3. A tote above both is not empty. A tote below either one may be.

In practice, a dirty tote is one where the product is plain to see: a puddle at the low corner, a ring on the wall, or a skin of material around the valve outlet.

Drain it, or hand it on

The first option is to drain it further. Tilt or pump it again, then measure. Many totes pass after a second pass. The second option is to wash. The third, if the product cannot be removed, is recycling of the parts. The fourth, if it is a hazardous waste with too much residue, is a hauler.

Why we say it plainly

We take no request for a tote that is not empty. A dirty grade is not a loophole. It describes a stage a tote passes through, not a place it stays.

Heel versus residue

Heel is the liquid left at the low point after draining. Residue is the film left on the walls. The federal test speaks of both at once, as an inch of residue on the bottom or 0.3% by weight. In practice a heel is what you measure with a rod, and a film is what you see with a light.