What "food-grade" means at the Graham Street yard

We will only call a used IBC tote food-grade when every single one of the following is true and documented in writing, by serial number:

1. The tote's previous contents are known and were themselves food-safe (syrups, juices, edible oils, sweeteners, honey, molasses, vinegar, non-acidic sauces, etc.).
2. We have a cleaning record from the previous holder OR we performed our own 4-stage cleaning cycle in-house.
3. The HDPE bottle shows no staining, no residual odor, and no stress-whitening that indicates past chemical contact.
4. The cage and valve are either original or replaced with food-safe-rated hardware.
5. A current UN/DOT label is present, matched to a clean-record serial in our log.

If any of those five are missing, we don't call the tote food-grade. It still gets a second life — usually as a standard tote, a rebottled unit, or a rework project. But it won't be labeled food-grade.

Our 4-stage in-house cleaning

When we can't rely on the previous holder's cleaning record, we run the tote through our own loop:

• Stage 1 — Hot rinse: 180°F potable rinse to flush residuals.
• Stage 2 — Mild caustic: NSF-approved food-surface detergent, 10-minute soak, agitation.
• Stage 3 — Hot rinse (again): 180°F potable rinse to remove detergent.
• Stage 4 — Air dry + QA: Inverted for 24 hours, then visual + odor inspection, then sealed.

Every stage gets logged against the chalk serial on the cage. That log is part of what you buy.

Typical previous contents

The food-grade totes that move through our yard came from:

• Regional craft-beverage blenders (simple syrups, flavor bases)
• Carolina honey and molasses producers
• Specialty vegetable-oil distributors
• Vinegar and fermented-sauce packers
• Dairy co-ops (non-fat liquid product, not finished product)

What we won't call food-grade

• Totes with unknown or undocumented previous contents
• Totes that previously held soap, sanitizer, or antimicrobial chemicals — even "gentle" ones
• Totes with visible staining, cloudy HDPE, or persistent odor after cleaning
• Anything we wouldn't put our own hot sauce in

For potable water

A food-grade tote can be suitable for potable (human drinking) water — but we strongly recommend a third-party NSF/ANSI 61 review by the end user. For rainwater catchment intended for non-potable use (gardening, apiary, livestock) food-grade totes are an excellent, economical choice.

FDA regulations: what actually applies to used IBC totes

The FDA regulates food-contact materials under 21 CFR Parts 174–186. For IBC totes, the critical regulation is 21 CFR 177.1520, which covers olefin polymers (including HDPE) intended for food contact. Here is what that means in practice:

• The resin must be FDA-approved. The HDPE used in virtually all major IBC manufacturers' bottles is FDA-approved food-contact grade. This applies to the resin, not to the finished container.
• The finished container must be clean and uncontaminated. A tote that previously held a food-safe product and has been properly cleaned is acceptable for food-contact reuse. A tote that previously held a non-food chemical is not — regardless of how well it was cleaned.
• The burden of proof is on the filler. The FDA holds the party who fills a container with food product responsible for ensuring the container is compliant. Our documentation exists to help you meet that burden.
• There is no FDA "used tote certification." The FDA does not certify individual used containers. When we say "FDA-compliant," we mean the materials, cleaning process, and chain of custody meet the requirements — not that the FDA has inspected the tote.

Our testing procedures

1. Visual inspection (pre-wash): Bottle examined under bright light for staining, discoloration, stress-whitening, crazing, and physical damage. Any of these = immediate rejection from the food-grade track.
2. Odor test (pre-wash): Experienced inspector sniffs the interior. Any persistent chemical, solvent, or fermented odor = rejection. Neutral or faintly sweet (typical of sugar syrups) = proceed.
3. 4-stage cleaning cycle: Hot rinse (180°F) → caustic detergent (NSF-approved, 10-min soak with agitation) → hot rinse (180°F) → 24-hour inverted air dry.
4. Visual inspection (post-wash): Interior re-examined for residual staining, film, or debris. Any visible residue = repeat wash or rejection.
5. Odor test (post-wash): Re-sniffed by a different inspector. Must pass independently.
6. Pressure test: 3 PSI held for 10 minutes. Any drop in pressure = valve or bottle compromise = rejection.
7. Documentation: Previous contents record, cleaning log, test results, and chalk serial number are compiled into a per-tote certificate.

Acceptable previous contents (expanded list)

We will consider a tote for the food-grade track if its documented previous contents fall into any of these categories:

Rejected previous contents (never food-grade)

The following categories permanently disqualify a tote from our food-grade track, regardless of cleaning:

• Industrial chemicals: solvents, degreasers, paint, coatings, adhesives, resins
• Agricultural chemicals: herbicides, pesticides, fungicides, growth regulators
• Cleaning chemicals: even "food-safe" sanitizers like quaternary ammonium compounds — the tote may be safe but we cannot verify residual levels
• Petroleum products: motor oil, hydraulic fluid, diesel, fuel additives
• Pharmaceutical intermediates: APIs, solvents, fermentation broth with non-food organisms
• Unknown contents: if we don't have documentation, we don't call it food-grade — period
• Any EPA-listed hazardous waste: regardless of concentration or cleaning

Shelf life and storage best practices

• Cleaned food-grade totes (empty): Store indoors, capped and sealed, away from direct sunlight. Use within 90 days of cleaning for best compliance. After 90 days, we recommend re-cleaning before filling with food product.
• Filled food-grade totes: Follow your product's specific storage requirements. HDPE is not a moisture or oxygen barrier for long-term storage (12+ months) — for extended shelf life, consider stainless.
• Temperature: Store between 40°F and 100°F for most food products. Freezing is acceptable for water and non-viscous liquids but may damage the valve gasket.
• Stacking: Two-high maximum, pallets aligned. Never stack food-grade totes under non-food totes.

Certification documentation you receive

Every food-grade tote we sell ships with:

• Chalk serial number (ties to our internal recond record)
• Previous contents declaration (product name and category)
• Cleaning record (date, method, inspector initials)
• Pressure test result (PSI, duration, pass/fail)
• Visual and odor inspection sign-off
• UN/DOT re-label date and specification

If you need additional documentation for your own food-safety audit (FSMA, SQF, BRC, etc.), email us with the specific requirements and we will format accordingly.