Intermediate Bulk Container Regulations

Posted on April 7, 2021 by Paige Pesko


Intermediate bulk containers, or IBC totes, are used in a variety of industries for a variety of purposes. Facilities may use them to store food, transport chemicals, and even ferment beer. They are capable of much, but even the most capable and multifaceted equipment can spark safety issues in a facility. For that reason, multiple national entities have established intermediate bulk container regulations to ensure the safety of factories and plants.

What Is Classified as an Intermediate Bulk Container?

We have discussed IBC totes at length in a previous blog. But to understand the regulations surrounding IBC totes, it’s necessary to first understand what the laws consider an IBC. The code of federal regulations defines an intermediate bulk container as “a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling.”

Classifications of IBC Totes

Different rules may apply to different categories of intermediate bulk containers, so it’s useful to address them beforehand. Although totes come in a number of varieties, such as rigid, folding, or flexible, the regulatory classifications typically focus on the material the totes are made from. Different materials receive different letters of the alphabet and are as follows:

  • “A” for steel
  • “B” for aluminum.
  • “C” for natural wood.
  • “D” for plywood.
  • “F” for reconstituted wood.
  • “G” for fiberboard.
  • “H” for plastic.
  • “L” for textile.
  • “M” for paper or multiwall.
  • “N” for metals other than steel or aluminum.

There are two parts of a tote, namely the inner receptacle and the outer packaging. These two parts may be made of a different material. When containers are placed into different categories, they are first categorized by the material of the inner receptacle, and then by the material of the outer package. For instance, you would categorize an IBC tote with a fiberwood interior and a stainless steel exterior as GA.

Occupational Safety and Health Administration (OSHA)

The occupational safety and health Administration, more commonly known as OSHA, is in charge of creating regulations that ensure American workers’ safety. This applies both to the setting and the equipment workers use, and because of that, they also have regulations dedicated to the safe use of totes.


Conducting proper testing of materials is essential for knowing whether they will be able to withstand the rigor of the task that is expected of them. OSHA provides several varieties of testing for IBC totes.

Strength Testing

All totes should undergo strength testing before they are deemed fit for service. This testing is designed to show the tensile strength of the storage container. The evidence that material has been strength tested is a seal from the American Society of Mechanical Engineers, American Petroleum Institute, or the Underwriters’ Laboratories, Inc. Our food-grade IBC totes all come sealed by the ASME.

Pressure Testing

Companies should perform internal pressure testing every thirty months. This testing is designed to ensure that the system can handle the maximum operating pressure and that there are no leaks or cracks in the system. For best results, check pressure in thirty-minute intervals to ensure there are no leaks.

National Fire Protection Association Rules (NFPA)

Caution is necessary when using IBC totes to store potentially flammable material. The National Fire Protection Association has regulations in place to keep workers and facilities safe under the Flammable and Combustible Liquids Code. This code applies to thirty-one states, including here in Texas.

Totes That Can be Used With Flammable Materials

As mentioned, IBC totes can be made with a variety of materials, from stainless steel to reconstituted wood. Naturally, containers that store flammable materials should be made from materials that are flame resistant. They should also be durable, especially considering that any cracks can lead to both the liquid and dangerous fumes escaping.

The NFPA recommends metal, rigid plastic, or composite containers for this. However, even in these instances, you should only store flammable materials in these containers if their closed cup flash point is 100 degrees Fahrenheit (or 38 degrees Celsius).

U.S. Department of Transportation (DOT)

Because of their stackable shape, intermediate bulk containers are ideal for storing food in transit. Because of this, the U.S. Department of Transportation has its own set of regulations for IBC Totes.


In any field, plants and factories should properly label the materials they are transporting. Because IBC totes are designed to carry a wide variety of materials, proper labeling of totes is especially essential. To avoid communication errors as materials are transported from one facility to another, the DOT has established standardized markings for IBC totes.

Markings should be printed legibly on the tote and should include information like:

  • The totes’ country of origin
  • The name and address of the manufacturer
  • The stacking test load
  • The dates of last inspections and applicable tests
  • The body material
  • The serial number

If the tote is designed to be dismantled after use, manufacturers should put separate markings on both the inner and outer receptacle of the tote. Manufacturers should also inspect and update shipping labels once every thirty months.


Those filling the IBC totes for shipping must inspect them every time they are being used to ship materials. A few items that should be noted during the inspection include:

  • Tote is free of damage, including cracks, corrosion, and contamination.
  • Tote is securely shut and no hazardous materials appear on the outside of the container.
  • The totes are properly marked and labeled according to regulations.
  • Inner lining has been changed if made of paper or cardboard.
  • The pressure settings of the tote are set to the proper rates.
  • The facility has filled the tote to the proper levels for safe travel.

Additionally, facilities must use the right container for the substance being transported. For instance, if a facility is trying to transport a liquid, they should use a metal, rigid, plastic, or composite IBC tote and avoid inner receptacles made of paper or cardboard. Or, if they are transporting a solid liquid that is prone to melting in transit, the tote should be made of material designed to handle solids and liquids.

Intermediate Bulk Container Regulations