There is a lot of misinformation when it comes to secondary spill containment, mostly from those peddling products that don’t actually do what they’re supposed to—contain spills. Much of that misinformation revolves around intermediate bulk containers (IBCs or “totes,” as they’re often referred to) but we’re here to clear things up, as a company that’s been in the spill containment and response business for 25+ years. Oh, and actually manufacture products that contain spills properly.
What is an IBC Tote?
IBC totes (intermediate bulk containers) are 275-gallon or 330-gallon storage containers designed to hold a wide range of chemicals and food-grade products. IBCs are most commonly made from high-density polyethylene (HDPE) and are impact-resistant, as well as resistant to heat, UV exposure, mold, mildew, and more.
Traditionally, IBCs are wrapped in a steel cage designed to protect the container itself and to help maintain its shape. The steel frame also has an integrated pallet to keep the IBC off of the ground, make it stackable, and allow the IBC to be moved with a forklift or pallet jack. On the top of the tank is a 6″ fill cap and, near the bottom of the container, a dispensing valve—both accessible through the IBC’s metal cage.
The most common outer dimensions of IBC totes, including their steel frames, are 48” x 40” x 46″, making them ideal for shipping on a standard shipping pallet.
Do IBC Totes Need Secondary Containment?
Yes. Per 40 CFR 264.175, a federal regulation which is enforced by the Environmental Protection Agency (EPA) in the United States, IBC totes containing hazardous materials or waste require a secondary containment system that has sufficient capacity to contain 10% of the volume of the container, or the total volume of the largest container, whichever is greater. The second half of that regulation applies when multiple containers share the same secondary containment system.
What Is a Hazardous Material as It Relates to 40 CFR 264.175?
Hazardous materials are defined a bit differently by the various federal agencies that regulate them—EPA, Occupational Safety and Health Administration (OSHA), Department of Transportation (DOT), and Nuclear Regulatory Commission (NRC). In our case, we’ll focus on the EPA’s definition, since that’s the administrator of 40 CFR 264.175. That said, even the EPA defines hazardous materials slightly differently across several documents and websites.
Here’s the bottom line in our case:
A hazardous material is any liquid that can cause harm to people, plants, or animals. In some articles, the EPA goes on to add how the chemical is released (e.g., by spilling, leaking, pumping, etc.) but that is irrelevant because the liquid is either hazardous or not on its own and, if it is hazardous, requires secondary containment when stored in non-portable containers, like IBC totes or 55-gallon drums.
What Are the Fines for Non-Compliance Of 40 CFR 264.175?
The fines for non-compliance of 40 CFR 264.175 are hefty at up to $25,000 per day. Yikes! To ensure your company is compliant—in the warehouse or on the job site—let’s take a look at all of the various available secondary containment solutions for IBC totes.
Secondary Containment Solutions for IBC Totes
There are several secondary spill containment solutions available for IBC totes stored either indoors or outdoors. Each has its advantages and disadvantages so you’ll need to consider your own requirements beyond complying with 40 CFR 24.175. Here are a few questions to consider:
- Will you need to move the containment system frequently?
- Will you be stacking multiple IBCs on a single, shared containment system?
- Will you need to dispense from the IBC regularly?
- Will you be storing flammable liquids in the IBC?
Indoor IBC Spill Pallets
A popular option for storing single or double-stacked IBC totes indoors is a heavy-duty, polyethylene spill pallet with a uniformly distributed load (UDL) of at least 10,000-15,000 pounds. An empty IBC tote can weigh between 100 and 150 pounds. Full of water or a similar liquid, an IBC could weigh upwards of 2,500 pounds. Polyethylene, or “poly” for short, is a great choice because it is so strong and also resistant to a wide range of chemicals.
Of course, UDL and chemical compatibility aren’t your only concerns when looking for a secondary containment solution for IBC totes. The sump of any IBC spill pallet needs to hold enough liquid to comply with EPA regulations in the event of a leak or spill. Similarly, if a dispenser is used with the tote, something needs to capture drips or leaks that may occur at or under that valve.
If we look at our own Ultra-IBC Spill Pallet, it meets most of these requirements with a 16,000 UDL capacity and a 400-gallon sump. Our more economical plus model IBC spill pallet has a lower UDL and sump capacity but still meets all secondary containment requirements for a single tote. The plus model is also forkliftable and incorporates slots for an optional bucket shelf to capture leaks and spills from a dispenser valve. Both pallets have removable grating and can be fitted with a drain for easy clean-up.
Outdoor IBC Spill Pallets
Since polyethylene stands up to weather and UV exposure for many years—especially when a UV inhibitor is part of the manufacturing process, as with our products—the indoor IBC spill pallets could be used outdoors. If it’s not covered, however, rain, dirt, and debris will fill the sump rendering it useless in the event of an actual IBC leak or spill.
For outdoor applications, a “hardtop” IBC spill pallet is recommended. These spill pallets are covered with either a hinged polyethylene top or a polyethylene roll-top to protect both the IBC tote and the secondary containment sump from the elements. Some units will include swing-out doors that open independently from the top for easy dispenser access. Ideally, both the top and doors should be lockable.
Fire-Resistant IBC Spill Pallets
If you’re storing flammable liquids in an IBC tote, you’re going to need a secondary containment system that is fire-resistant, since polyethylene will melt in a fire. Galvanized steel IBC spill pallets offer both fire and corrosion protection for use indoors or out. Just like polyethylene spill pallets, you’ll need a covered solution for outdoor use to keep the sump clean and dry.
Steel hardtop spill pallets for IBCs are covered spill pallets designed for long-term outdoor use. They’re usually surrounded by steel with a top that may or may not open, and one or two steel doors. Again, if the top opens, both it and the doors on any outdoor hardtop spill pallet should be lockable.
As you can see, there are quite a few options for safely storing IBC totes both indoors and outdoors, while also meeting or exceeding secondary containment regulations. To avoid violations and fines, make sure you get the right solution based on what you’re storing, how, and where. It seems like obvious advice but during our on-site facility audits, we commonly see IBC totes incorrectly sitting on top of secondary containment systems (or lack thereof) that are not designed for IBCs.