Guide
Storing empties outside until they go
Keep empty totes outdoors only with caps closed, the old label on and rain kept out, and keep them out of the sun when you can. Rain in a tote that held a chemical makes a new waste.
Caps on, and why rain matters
A chiller yard or a loading apron has no room for a warehouse, so empties wait outside. The first rule is closed caps. An open fill cap lets rain into a tote that held a chemical. The rain mixes with the residue, and a tote that was RCRA empty is suddenly a tote with a heel of contaminated water.
The second rule is the vent. A closed cap on a tote that sits in the sun builds pressure, so leave the vent clear.
Rain that gets in becomes a waste of the same kind as the last product. It belongs to the generator, and it can push the tote back over the rule.
Sun, UV and age
High-density polyethylene bottles are made with a UV stabilizer, but they are not made to stand in full sun for years. A bottle that sits outdoors for a season goes chalky and stiff, and it can craze near the fittings. A tote that had a long reuse life in a warehouse can lose it on a pad.
Where you can, stand empties in shade, against a north wall, or under a cover. A tarp is better than nothing, as long as it is tied so it does not trap water on top of the cage.
Stacking and footing
Container Exchanger says empty totes can be stacked three high, and the IBC specifications page says caged poly totes of 275 to 330 gallons can be stacked four high when empty. Both are about empty totes on a solid, level surface. Check your own site rules, and never stack a tote that is not empty.
- Level, hard ground, not grass or gravel that can shift.
- Cages aligned over each other, pallet bases not overhanging.
- A forklift lane left clear along one side.
- Totes of the same last contents together, so a leak is easy to trace.
Marking what waits
Keep the old label on and write the date the tote was emptied on a tag or tape on the cage, with the heel you measured. When the truck comes, the record travels with the tote.
If totes are piling up faster than they leave, the removal page explains how to count and stage a run. For a short wait, the pickup-ready checklist is the thing to follow.
Keep reading
- Clearing a dock or yardHow to get a run of emptied totes off a loading dock, chiller yard or lab with little room: count, grade, stage and request removal.
- Pickup-ready checklistCaps and valve closed, old label on, SDS to hand, cage intact and room for a forklift or pallet jack: the checklist before a truck comes.
Sources
- 330 gallon IBC tote dimensions (Container Exchanger)
- IBC tote specifications (ibctanks.com)
- 40 CFR 261.7, Residues of hazardous waste in empty containers (Cornell LII)
Last reviewed . General guidance, not legal advice.