Three states, three rulebooks for empty totes

01Three agencies

The table names who to ask. It does not summarise the state rules, which differ in detail and change. Read the agency’s current guidance.

02What is the same

The federal baseline is 40 CFR 261.7 for empty containers and 49 CFR 180.352 for the requalification of IBCs. A tote over 119 gallons that held hazardous waste is empty at 0.3 percent of capacity by weight or one inch of residue, and a tote for liquids needs a leakproofness test every 2.5 years. Those apply on both banks of the river.

03Crossing the river

Selling on the Pennsylvania side and buying on the Jersey side is normal here. A tote that starts in Philadelphia and ends up in Gloucester County crosses a state line and the agency that applies may change with it. The ticket says where each end of the move sits, so the desk can ask the right questions.

The desk takes empties, never waste. A tote that is not empty under the rule is not the desk’s to move, in any of the three states.

04Where the desk’s counties are

Pennsylvania: Philadelphia, Delaware, Montgomery, Bucks and Chester. New Jersey: Burlington, Camden, Gloucester and Salem. Delaware: New Castle. Each has an area page with its ZIPs, industries and the agency to ask.

05Post the ticket

+More in Guides

• RCRA emptyWhat 40 CFR 261.7 says about empty totes over 119 gallons, when a triple rinse is required, and what that means before a tote is sold.
• AreasWhere Philly IBC Totes trades: Philadelphia, its Pennsylvania counties, South Jersey and northern Delaware, county by county and district by district.
• SellPlants, blenders and farms in PA, NJ and DE: post your empty IBC totes with size, count, last contents and SDS, and the desk finds the buyer.
• New Castle County, DEDelaware City refining, the Port of Wilmington and Newark labs.
• Reading the UN plateEvery mark on an IBC's UN plate explained: 31HA1, packing group letter, manufacture date, stacking test load and maximum gross mass.
• StackingHow many totes can stack, empty or full, depends on the tote: why the answer is on its UN plate and what else to check.
• Retest datesThe 2.5-year leakproofness test, the 5-year internal inspection, and what an out-of-date tote is still good for.
• Dimensions and weightsFootprint, height, capacity and empty and full weights for 275 and 330 gallon totes, with gallons, liters, pounds and kilograms checked.
• 275 vs 330How a 275 and a 330 gallon tote differ in height, capacity and use, and which one a plant, a farm or a gardener should ask for.
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