Retest and inspection dates on a tote

The three checks

Leakproofness test. Before first use and every 2.5 years after, the IBC is pressure-tested for leaks under 49 CFR 180.352(b)(1). The closures don't have to be fitted for the test.

External visual inspection. Once after production and then every 2.5 years, someone checks the marking is complete and readable, the service equipment (valve, cap, vents) works and isn't damaged, and the body and cage have no cracks, warping or corrosion. On a composite tote the bottle is taken out of the cage for this unless the cage is welded or riveted so that removing it would damage the cage.

Internal inspection. At least every five years, the inside of a metal, rigid plastic or composite IBC is checked for cracks, warping and corrosion. On a steel IBC the wall thickness is checked too.

When the clock starts

From the date of manufacture, or from the date of a repair that meets the rule. That is the month and year on the plate. The latest test and inspection dates are marked on the plate's second block (49 CFR 178.703(b)).

The date governs filling, not shipping. An IBC whose test is due may not be filled and offered for transport until the test is done, but a tote filled before its due date can still travel (180.352(a); 173.35(a)). A shipper who fills a tote the week before it is due can send it out; one who fills it the week after cannot.

Records the owner keeps

Whoever owns or leases the IBC keeps the test and inspection records: the design type, dates, where and by whom it was tested, and the results. They are kept at each location where testing is done until the next test is passed, or for at least 2.5 years, and shown to DOT on request (180.352(g)). For a fleet of totes that go out to customers and come back, that is a real administrative load, and it is one reason some shippers send totes one-way and buy new.

Why a new tote helps

A new tote's date is weeks old when it reaches you, so it starts with nearly the whole 2.5 years. For a product that sits in a customer's tank farm for months, or a fleet that turns slowly, that is time with no retest due. If your cycle is long, say so when you ask for a quote and ask what date of manufacture the totes will carry.

Plate date	Next leakproofness test and external inspection	Internal inspection by
Month of manufacture	2.5 years later	5 years later
After a qualifying repair	2.5 years after the repair	5 years after the repair

Planning your fleet

If you buy totes in batches, their retest dates fall due together. Keep a list of each tote's serial or plate details and its manufacture date, and look ahead six months. Then decide in good time whether to test, retire or move each tote to non-regulated service, rather than finding a whole batch out of date on the day of a shipment.

Who may test

Retests and inspections are done by or for the owner, often by a tote reconditioner or a testing service, and recorded with the IBC's details. A new tote arrives with a recent manufacture date, so its first test falls well ahead; a used one may already be close to it.

Short answers

Does a tote for water need retesting?

The 180.352 schedule applies to IBCs used for hazardous materials. A tote holding water or a non-regulated product isn’t on that clock, though inspecting it is still good practice.

Can I ship a tote that is past its retest date?

If it was filled before the due date, yes. An IBC whose test is due may not be filled for transport until it has been tested.

Who keeps the test records?

The owner or lessee of the IBC, at each location where the tests are done, for at least 2.5 years or until the next test.

Do totes for non-hazardous products need retesting?

The US retest rules apply to IBCs used for hazardous materials. For other products, inspect them before each fill anyway.