Dirty totes and the heel
A dirty IBC tote still holds visible product, a heel above what pumping removes. It goes to a washer or the recycler, not straight to reuse. In waste terms it may not yet be RCRA empty.
Last reviewed November 11, 2026
What it looks like
The bottom of the bottle holds liquid or sludge. The walls may carry a ring where the level sat. The smell is strong. The valve may leak slightly because of crusted product.
You do not need a flashlight. If you can see the heel from the cap, the tote is dirty.
How a tote gets this grade
A tote is dirty when the heel is more than pumping can reach, or when product has dried on the walls. The line that matters for hazardous waste is in 40 CFR 261.7: for a container over 119 gallons, no more than one inch, or 0.3 percent of capacity by weight, left in the bottom.
Above that line, the tote is not empty, and handling it rightly depends on what the product was.
The jobs it suits and the ones it never does
Suits
- A commercial washer.
- The recycler for bottle and cage.
- A buyer who wants parts.
Never
- Any reuse as it stands.
- Water of any kind.
- Transport without the SDS.
What to check before you say yes
- What the heel is. Look for the SDS.
- How much is left.
- Whether the valve leaks.
- Who is the generator of the waste, if it is waste.
In South Florida
Dirty totes pile up where product moves fast: warehouses, fuel-side businesses and chemical blenders. The cost of a dirty tote is a washer visit or a recycler, and the sooner you know which, the sooner the dock is clear.
In summer, a dirty tote left in the sun also grows a smell and softens the heel. Cover it, label it and move it.
Mistakes we see
- Pouring the heel on the ground.
- Selling a dirty tote as as-is.
- Leaving it uncovered in rain, which fills the bottle.
- Moving it without the SDS.
Reading the paperwork and the plate
Before anyone handles a dirty tote, read the safety data sheet for the heel and wear the gloves, eye protection and footwear it calls for. Work in open air, away from storm drains, and keep absorbent material and a catch pan under the valve. A heel that spills on concrete in Miami-Dade becomes a spill report very quickly.
Write down the count, the size and the condition of every dirty tote before you ask anyone to collect them. A washer or a recycler will quote from that list, and a list that says the heel is a known food syrup is treated very differently from one that says only unknown liquid.
Next to its neighbors
| Grade | Bottle | Where it usually goes |
|---|---|---|
| As-is | Pumped out | Same-product reuse |
| Dirty | Heel left | Washing, recycling |
| Damaged | Broken | Parts, recycling |
Questions people ask
How long can a dirty tote wait before collection?
Keep it closed, shaded and out of rain. In summer heat the heel softens and smells, so move it sooner rather than later.
Does the size of the heel matter?
Yes. Under about an inch is usually pumpable; beyond that the tote needs a washer, and the paperwork may change if it held a regulated product.
What is a heel?
The product left in the bottom of the bottle after pumping. It is also called residue.
Is a dirty tote waste?
It may be. If it held hazardous waste, the 40 CFR 261.7 test for empty applies. Ask your environmental manager.
Can I wash it myself?
Only if you know what it held. Some products need a specific procedure and disposal of the rinse.
Do you take dirty totes?
We take the request. Send the count, the size and the SDS.
Does rain change the grade?
Rainwater in a dirty bottle is a heel with more water in it, not a rinse.
Tell us about dirty totes
Send the count, the size and the SDS. We say what happens to each.