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IBC Recycle USA
Blog · July 19, 2022 · 7 min read

FSMA and IBCs: What the Food Safety Modernization Act Actually Requires

The Food Safety Modernization Act (FSMA) governs a lot of how food ingredients move through the U.S. supply chain. For IBC tote intake specifically, the requirements are narrower than most procurement teams assume — but the documentation expectations are higher than most reconditioners realize. Here is the lay of the land.

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What FSMA actually requires for incoming IBCs

For Preventive Controls for Human Food (PCHF) facilities receiving IBCs of food ingredients, the regulation focuses on receiving verification: that the container is suitable for food contact, that it has not been contaminated in transit, and that prior contents (if applicable) are documented as food-grade.

There is no specific FSMA prohibition on reconditioned IBCs. There is an expectation that the receiving facility can demonstrate it verified suitability of the container.

What food-facility receiving teams should require

  • Container suitability statement (resin grade or reconditioning documentation).
  • Prior contents history (for reused containers).
  • Wash and certification documentation (for reused containers).
  • Tamper-evident seals or equivalent receiving verification.

What we provide

For food-grade reconditioned tanks, a full lot package including prior-contents documentation, wash recipe, post-wash verification (pH, swab where applicable), and resin specification for the bottle. Most food-facility receiving teams find this exceeds what their own SOPs require.

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