Guide
Last contents: the one thing to know about a tote
The last contents decide a tote’s next life: reuse for the same product, reconditioning, or recycling. The safety data sheet for that product is the first document anyone asks for before a tote moves.
Why the last contents come first
A tote is a bottle with a memory. High-density polyethylene takes up traces of what it holds, and a cage and valve carry residue in places a rinse does not reach. That is why a food ingredient tote, a glycol tote and a biocide tote end up in three different places even when all three are empty.
The grade comes from the history. A tote that only ever held a food ingredient can be reused or sold for food or water use if the paperwork shows it. A tote that held an industrial chemical can be reused for the same product, reconditioned, or recycled. A tote that held something unknown is a recycle-only tote.
Where to find them
- The old product label, usually on the bottle or the cage, with the product name and the supplier. Do not peel it off.
- The delivery paperwork, which names the product by its trade name and often its supplier.
- The SDS, which the site keeps for every product it stores. It gives the specific gravity, the hazards and the cleaning guidance.
- Your purchasing records, if the label has gone.
If none of these survive, say so. Unknown is a legitimate answer on the request. It is better than a guess.
What the SDS tells you
The SDS gives the specific gravity that the Empty Check needs, the hazard class that tells you whether the tote may be hazardous waste, the compatible cleaning liquids, and the first-aid and spill notes. It also names the supplier, which is sometimes a take-back route for the product.
| Last contents | Usual next life | What to send |
|---|---|---|
| Food or beverage ingredient | Food-grade history, reuse or sale | Supplier name, product, dates, proof of food-only use |
| Non-hazardous chemical | Reuse for the same product, reconditioning or recycling | SDS, tote size, retest dates |
| Glycol or cooling-water treatment | Recycling or reconditioning | SDS and specific gravity |
| Hazardous chemical with an SDS | RCRA empty first, then recycling | SDS and the Empty Check ticket |
| Water or rinse only | Reuse or reconditioning | A note on what the water was |
| Unknown | Recycle only | Anything on the tote that gives a clue |
What to send with a request
Name the last contents in the message box of the pickup request. Add the size, how many totes, and whether the SDS is to hand. If a tote holds more than one product over its life, name the most hazardous one.
Run the Empty Check first when you can. Its ticket carries the contents, the capacity, the heel and the verdict into the request. Whether a tote is empty is the generator's decision, and the generator keeps the SDS.
Keep reading
- The UN plateWhat 31HA1, the packing-group letter, the manufacture date and the retest date on a tote's plate mean for reuse and recycling.
- Request a pickupRequest pickup of empty IBC totes in the DC metro. Tell us size, grade, last contents and truck access, and send the SDS if you have it.
- Chemical emptiesTotes that held glycol, biocides, reagents or coatings: what is needed before they can be reconditioned, rebottled or recycled.
Sources
- 40 CFR 261.7, Residues of hazardous waste in empty containers (Cornell LII)
- 21 CFR 177.1520, Olefin polymers (Cornell LII)
Last reviewed . General guidance, not legal advice.