Rules from federal, state, and local agencies can apply to how IBC totes are made, used, moved, and disposed of. Which ones apply to you depends on what is in the tote, where it is, and whether it travels on public roads.
This guide is a general safety and planning overview for businesses in the Chicago area. It is not legal advice, and rules change. Before you rely on anything here, check current regulations or speak with a qualified safety or compliance professional.
Understanding UN Markings
Totes meant for shipping hazardous materials carry a UN marking that says what the design was tested for. Not every tote has one, and a marking on a used tote does not by itself mean the tote is fit for your use. It is still the best place to start.
What a UN Marking Tells You
Layouts vary, but a marking on a tote or its plate commonly includes these items:
Packing groups matter because they rank danger: group I is the highest and group III the lowest. A tote marked Y was not tested for group I materials.
Plate Dates
Most composite totes have a plate showing the 2.5- and 5-year test dates. These periodic tests apply to totes in regulated service. A tote past its dates may look perfectly fine and still not be usable for that purpose. If you ship regulated materials, check the plate before each use, and check current regulations for what the dates require.
Transportation Rules
The U.S. Department of Transportation regulates moving hazardous materials on public roads, largely through 49 CFR. In general terms, those rules cover how packaging is tested, how it is filled and closed, and what labels and shipping papers go with it, along with driver and employee training. Cargo securement rules can apply even when contents are not hazardous. For a practical look, see transporting IBC totes.
Workplace Safety
OSHA sets workplace safety standards that can affect how totes are handled and stored. The main areas to review are:
Hazard Communication
Containers of hazardous chemicals generally need proper labels, safety data sheets should be available, and workers should be trained on the hazards they handle.
Flammable and Combustible Liquids
These bring extra concerns, including storage location, ventilation, ignition sources, and static during transfers. Plastic totes may be restricted for some flammable liquids, so check fire codes and speak with your local fire authority first.
Material Handling
Store totes so they cannot tip, fall, or collapse. Keep aisles clear, and use lifting equipment suited to the load. A full 275-gallon tote of water weighs well over a ton, so it needs a forklift or similar equipment.
Spill Response
Keep spill kits suited to your materials close by, and train people to use them. See the spill containment guide.
Environmental Rules
EPA rules can affect tote users in a few main ways:
- •Hazardous waste: A tote that holds hazardous waste, or held it, may need specific labeling, storage, and disposal handling.
- •Spill prevention: Sites storing oil above certain amounts may need a Spill Prevention, Control, and Countermeasure (SPCC) plan. Vegetable oils and animal fats can count too.
- •Water protection: Releases that could reach waterways or storm drains can bring reporting duties.
Thresholds and details change, so check current regulations for your site.
Labeling Basics
Labeling is an easy place to slip up, particularly with reused totes. Use this as a starting list:
Labeling Checklist
Illinois and Local Rules
State and local requirements can add to federal ones for sites in the Chicago area:
- •Illinois Environmental Protection Agency: State rules cover waste and environmental protection, so check them if you store regulated materials or waste.
- •County and city fire codes: Local codes may limit what you can store and where. Your local fire marshal is the right contact.
- •Stormwater: Outdoor storage can raise stormwater questions, so keep totes covered and contained where you can, and ask whether a permit applies.
Good Practices for Any Site
- Log your totes: Note each tote's dates and contents, and set reminders ahead of plate dates.
- Inspect often: Do a quick visual check before each use, and keep notes.
- Label right away: Label a tote when it is filled, and remove old labels when the product changes.
- Train people: Everyone who handles totes should know the basics of safety, labels, and emergency response.
- Ask suppliers questions: Ask what a tote held, how it was cleaned, and what records are available.
- Keep records: Hold on to purchase, inspection, cleaning, and disposal records.
Finding Totes for Your Operation
IBC Recycling Chicago takes requests from Chicago and the Chicagoland area and passes them to partner suppliers. It does not give compliance advice, and it does not handle or ship regulated materials. Include your product and intended use in your request so a partner supplier can tell you what is available. Pricing comes by quote. Request a quote and a partner supplier follows up.
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