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Prepping totes for a SQF or BRC inbound audit

April 9, 2025·10 min read·By Maya Trousdale
food gradeauditscompliance

If you’re a food or beverage manufacturer with SQF, BRC, or FSSC 22000 certification, inbound packaging is a documented control point. Auditors will check your supplier files, your inbound inspection records, and a sample of receiving documentation against what physically arrived. Here’s what we’ve learned over five years of supporting customers through audits.

The 11 dock-side checks

From our customers’ checklist composites:

  1. Tag present on tote, listing prior contents, wash date, and supplier identifier
  2. Visual inspection of bottle interior through top hatch — no residue, no discoloration, no biofilm
  3. Top hatch gasket present, compressed, not cracked or hardened
  4. Bottom valve closed and seal-tagged with breakable plastic tag
  5. Cage clean, no rust transferring to bottle
  6. Pallet plastic or food-grade composite, no wood
  7. UN/DOT markings present if hazardous prior contents (regardless of current intended use)
  8. Wash certificate or equivalent documentation matching the tag
  9. No physical damage to bottle (cracks, deformation, valve damage)
  10. Supplier letter of guarantee on file (one per supplier, not per tote)
  11. Allergen status disclosed for any tote that previously held an allergen-containing product

The documentation packet

Every Grade A tote we ship includes a one-page document with: prior contents (last fill), all known previous contents going back as far as records exist (we keep tote-level histories on the major brand bottles), wash protocol used, technician initials, wash date, discharge pH from final rinse, and our food-contact letter of guarantee referencing 21 CFR 177.

We also email the customer a digital copy at ship time so the receiving team has it before the truck arrives. The number of customer audits that have hinged on having documentation in hand on the day of audit is non-trivial.

Allergen disclosure

This is where most yards fall short. The eight major food allergens (FDA) plus sesame (since 2023) and the receiving customer’s own specific exclusions (gluten, certain colors, sometimes labels like “non-GMO”) all need to be disclosed if the tote ever carried them, even once. We track allergen history at the bottle level and decline food-grade designation on bottles that previously carried major allergens unless the customer is comfortable receiving an allergen-marked unit.

The traceability gap

The honest weak link in IBC food-grade work is that bottle history before the most recent fill is rarely complete. We buy mostly from a few large customers whose previous-contents records we trust, but the open-market bottle has unreliable history. We don’t sell open-market bottles as food grade for this reason. If a yard sells you a food-grade tote and can’t tell you the prior contents, that yard’s definition of food-grade isn’t one your auditor will accept.

The audit-day script

If an auditor asks about your tote supplier and the answer is “they have a website,” that’s a finding. Have on hand: supplier’s wash protocol document, supplier’s letter of guarantee, your inbound inspection records for the last 12 months (a sample is fine), and the wash certificate for the specific totes the auditor inspected. If you don’t have these, ask your supplier for them today, not the day before audit.

Questions on this one? Email info@ibctankscleveland.com. We answer everything inside one business day — usually inside four hours.

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