Food-grade vs industrial: how the line is actually drawn

Three things decide whether a used IBC can carry the food-grade reconditioned label, and they have to be true together. Miss any one and the tote drops to industrial.

1. The first life held a food-contact substance. Not "probably food." We need labels, paperwork, or a chain-of-custody document that says the previous fill was an FDA-approved food contact substance under 21 CFR 175 or 177. If we can't prove it, it's industrial.

2. The wash holds. Our 7-step protocol (pre-rinse, caustic recirculation, citric neutralization, sanitizing rinse with peracetic acid, multiple HP rinses, sampled final rinse, UV inspection) has to come back clean. The sample is bench-tested for residual organics and TOC. If it doesn't pass, the tote gets a re-wash or drops to industrial.

3. The bottle and gasket are sound. A bottle with deep crazing, surface scoring or visible permeation residue can't be food-grade no matter how clean the rinse. Same for a gasket that's swollen or hardened — we replace it as part of the cycle, but if the seat itself is damaged, the tote isn't food-grade.

What this means in practice: when you see "food-grade reconditioned" on one of our totes, you can ask for the wash log and see all three checks. We keep them for two years.

What it doesn't mean: an industrial-grade tote is dirty. Most of our industrial inventory is clean enough for any non-food use; it just doesn't have the paper trail or the 7-step wash that food contact requires.

A common confusion: customers sometimes ask whether a tote that previously held propylene glycol food-grade can be reused for olive oil. The chemistry is benign in both cases, but the chain-of-custody is what matters. If the propylene glycol came from a food-cert supplier with paperwork, the tote stays food-grade. If it came from a generic chemical distributor with no FDA-grade letter, it doesn't, regardless of how clean the molecule is.