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Reference · May 4, 2024

Why "Food Grade" Alone Is Almost Meaningless

There is no federal regulator defining "Grade A." Here's what to ask when a tote vendor uses the phrase casually.

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RM
Reyna Mata
7 min read · May 4, 2024

A buyer called us yesterday and said the magic words: "I just need a food-grade tote." That's a fine starting point, but it's worth unpacking what it actually means, because the answer most vendors give is "yes, we have that" without doing the underlying work.

The label is a convention, not a regulation

There is no federal standard for "Grade A IBC tote." The FDA regulates the resin and the manufacturer, not the reconditioner. The grade you see is an industry convention — one reconditioner's Grade A can be roughly equivalent to another's Grade C, and there is no auditor walking the country making sure the labels line up.

What the grade should mean

When we use the term Grade A, we mean:

  • The prior fill was a food-contact material (syrup, edible oil, brine, juice, beer wort, glycerin, vinegar, honey, molasses, citric acid)
  • The tank passed our intake inspection for cosmetic, structural, and valve condition
  • The tank went through our six-stage reconditioning: hot rinse, caustic wash, neutral rinse, potable polish, gasket replacement, chain-of-custody tagging
  • The chain-of-custody tag is affixed at the cage on outbound day, listing prior fill, wash dates, gasket, lot number

That's a six-step process and a documented audit trail. Other reconditioners might omit any subset and still call it Grade A.

What to ask a vendor

A four-question litmus test:

  1. What was the prior fill of the specific tank I will receive?
  2. What wash process was used, in what sequence?
  3. Was the gasket replaced, and with what material?
  4. Can you produce a chain-of-custody document at the time of delivery?

Vendors who can answer all four are running a real process. Vendors who can answer one or two are usually doing a hot rinse and calling it food grade.

What's at stake

If you mis-grade a tote into a food-contact application and the tote was previously holding a non-food residue, you have a recall on your hands. A copacker audit catches it. The cost of a recall is roughly six orders of magnitude higher than the cost of asking the four questions up front.

The grade label is a starting point. The chain-of-custody tag is the actual answer.