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Who Signed Off on Your Totes?

  December 2016 / January 2017

Who Signed Off on Your Totes?
By: Gary R. Brown, P.E., President, RT Environmental Services, Inc.


There is increasing recognition that intermediate bulk containers (IBC), commonly known as totes, are more widely used as a cost effective and easily handled container for liquids. Liquids are used at industrial sites, drilling sites and at construction sites, and totes rather than drums are used for storage with increasing frequency. Unfortunately, in many instances totes have been introduced to project sites, work sites and industrial sites without the use of totes being properly considered in federal Spill Prevention Control and Countermeasure Plans and related state Contingency Plans.

ongmarketplace_totesThe key technical difference between totes and other forms of containment is that totes can unfortunately be speared by forklifts and totes are simply not a material (such as metal) that offers the same resistance to ignitability and flammability concerns as do drums. Also, because totes when stacked have substantial capacity, totes in reasonable quantities are replacing small above-ground storage tanks in many instances. The reason for this is that unloading of a totes is simple, as compared to transfer of liquids from tanker trucks to tanks which takes time, and usually involves pumps, valves and labor.

RT Environmental Services, Inc., whose principal, Gary R. Brown, P.E., Q.E.P., is a Registered Professional Engineer in 22 states including the District of Columbia, felt it important to share details on what are appropriate Best Management Practices and procedures to be implemented where the use of totes is being incorporated into an SPCC or other Contingency Plans, as a form of liquid containment.

Although the placement and use of totes would appear to be relatively simple, there are actually a significant number of considerations to be taken into account, when the placement and use of totes is considered at any location where ongoing use will continue.

Important questions regarding the placement and use of totes are:

– What will be the class of the liquid stored?

– Where materials will be flammable or combustible, what codes will apply?

– Will code officials require secondary containment and, if so, which type?

– In the event of a spill incident or incident regarding flammability or fire, what tote layout has been selected and why?

– Unlike drums, totes cannot always be accessed from all sides, and the typical tote layout, which may include stacking, only allows straight line row access. If the access is to be straight line, how many totes can be permitted to be laid out and stacked so that the response time to retrieve a problem tote will not result in an expanding emergency leak or flammability situation?

– If accessibility to a problem tote is important, should the totes be stacked so that access is sideways, directly into the row and not along the row, to reduce the stack movement/ tote access time?

– If totes are being aggregated in an area for the first time, and the materials are combustible or flammable, does the fact the totes are being aggregated change requirements for fire protection, including sprinklers and/or such units as halon so that insurance requirements to be code compliant are not compromised?

– Accidental spearing of totes by forklifts is a key problem emergency incident mode. This is associated with totes but is not normally associated with the container method that the totes replace, including the use of drums or tanks. Because of this, the tote storage area, prior to being finalized, should be evaluated as to how “busy” the area will be, particularly with forklift traffic. Totes, if more than a handful are involved, should only be placed in areas where access is well thought out as to the avoidance of forklift spearing incidents and meeting code requirements. Although drums are typically viewed as temporary storage, as the volumes stored increase, interpretation of code requirements that there is now “permanent storage” may require upgraded fire protection, include aisle spacing changes or other safety measures.

– If the stored materials are flammable or solid, what is the require code classification for wiring/electrical systems, and are there unprotected drains nearby the planned tote storage area?

– If there are drains nearby, and there are oils, flammables or combustibles involved, are the floor drain systems set up so that spilled or washed down liquids will flow through an oil/water separation system which meets the requirements of local or regional sewer authorities?

– Are all totes arranged so that markings and/or labels are visible from the aisle?


Best Management Practices
– Decide whether tote storage must be added to your Contingency Plan and/or Stormwater Management Plan.

– Place appropriate spill kit(s) in tote storage and loading/unloading areas.

– Have a Professional Engineer or Code Official determine:
o Material compatibility/separation requirements
o Appropriate aisle spacing and stacking arrangements
o Layout, forklift access and storage layout logistics
o The need for tote group or individual secondary containment

– Include tote loading/unloading and fork lift movement aspects in Contingency Plan Training.

Totes can be a big improvement in liquids management and labor and liquid handling costs can be reduced. But remember – changing the containers you use means that you are responsible to evaluate safety, building code spill response and stormwater management to assure continuing environmental and code compliance.

Contact Information:
Gary R. Brown, P.E.
RT Environmental Services, Inc.