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Compliance · October 14, 2025

What an auditor actually asks about your containers

Customers tell us what their auditors asked, and after enough of these conversations the list stops varying. There are about seven questions, and every one of them is answerable from records you either have or do not.

What an auditor actually asks about your containers
Fig. 01Quality, food safety and transport audits keep coming back to the same handful of container questions. Knowing them in advance turns an audit finding into a filing exercise.

Short answer

Auditors ask for prior-contents provenance, cleaning evidence, test records, traceability from container to batch, segregation practice, and how you decide a container is unfit. Have the records before the audit, not after.
Published
October 14, 2025
Reading
5 min
Desk
Certification Bench
Topic
Compliance
Form 01 · Spec request

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None of these are trick questions. They are all versions of the same underlying one: can you demonstrate what you claim, or are you telling me?

1. Where did this container come from and what was in it before?

Provenance. A prior-contents record naming the product and the shipper, supplied by your container supplier and retained by you. If your supplier does not issue them, this question has no good answer.

2. How was it cleaned, and what evidence do you have?

A wash certificate naming the container serial, prior contents, the wash cycle applied, the date and the operator. "It was cleaned" is not evidence. A per-unit record is.

3. How do you know it does not leak?

A pressure test result. Ours is a sealed 3 psi hold, recorded per unit. For containers in regulated transport service, add the leakproofness test record and the date it was marked.

4. Which batch went into which container?

Traceability, and the question that most often produces a finding. Recording the container serial against the batch turns a potential recall investigation into a lookup, and it costs one column in a spreadsheet.

5. How is food-grade stock kept separate from everything else?

Segregation, evidenced by practice rather than intention. A dedicated storage area, dedicated handling equipment, and containers that never share a wash shift with industrial stock. Segregation that exists only on a policy document is not segregation.

6. How do you decide a container is no longer fit for use?

A stated rejection criterion. Ours is crazing, stress whitening, permanent deformation, retained odour after two full wash cycles, or any pressure decay after the gasket has been replaced.

An auditor is not looking for a particular answer here. They are looking for evidence that somebody decided in advance rather than case by case.

7. What happens to containers when you are finished with them?

Increasingly common, and driven by sustainability reporting rather than safety. A diversion statement showing units and tonnage split by reuse, rebottling, repair and material reclaim answers it directly.

What to hold on file

  1. 01Prior-contents record per container or per lot.
  2. 02Wash certificate per unit for anything reconditioned.
  3. 03Pressure test result per unit.
  4. 04Design-type plate photograph and leakproofness test date for regulated service.
  5. 05Container serial recorded against every batch filled.
  6. 06Your own written rejection criteria.
  7. 07Diversion statements for containers sent for reclaim.

Every item on that list is something a container supplier can issue as standard. If yours does not, the gap in the audit is theirs and the finding is yours.

Preparing in an afternoon

If an audit is scheduled and the records are patchy, this is the order to fix things in.

  1. 01Write down your rejection criteria. One page. It is the question most likely to produce a finding and the easiest to answer.
  2. 02Start recording container serials against batches today, even if you cannot backfill. A control that starts is better than one that is planned.
  3. 03Ask your container supplier for wash certificates and prior-contents records for stock you already hold. Most can reissue.
  4. 04Photograph the design-type plates on anything in regulated service.
  5. 05Write a short segregation statement describing how food-grade containers are stored and handled, and make sure it describes what actually happens.

None of that requires new equipment and all of it produces a document.

The difference between a finding and an observation

Auditors distinguish between a control that does not exist and one that exists but is not evidenced. The second is far cheaper to close.

If you inspect containers on receipt and reject the bad ones but write nothing down, you have the control and not the evidence. Adding a one-line log converts a potential finding into a demonstrated practice, and it takes seconds per container.

What suppliers should be giving you as standard

Documents a container supplier should issue without being asked
DocumentApplies toFrequency
Prior-contents recordReconditioned and food-grade stockEvery unit
Wash certificateAnything reconditionedEvery unit
Pressure test resultAnything reconditioned or rebottledEvery unit
Leakproofness test recordRegulated serviceEvery unit, per test cycle
Design-type plate photographRegulated serviceEvery unit
Diversion statementContainers sent for reclaimPer load or period

If your supplier issues none of these, the gap will show up in your audit rather than theirs. That is worth raising before the audit rather than after it.

The question behind all the questions

Every item on the auditor's list is a version of: can you show me, or are you telling me? Records answer the first. Confidence only answers the second, and confidence is not evidence.

Questions about audits

Which audits ask about containers? Food safety schemes most consistently, quality management audits frequently, and increasingly customer sustainability questionnaires — which are not audits but produce the same document requests.

Do auditors inspect containers physically? Sometimes, briefly. What they mostly do is ask you to demonstrate a control and then look for evidence it is applied. The container is a prompt for a records question.

What if our supplier cannot provide records? That is a supplier problem that becomes your finding. It is worth raising with them before an audit, because most reconditioners can produce records and simply do not unless asked.

How far back should records go? As far as your scheme requires, and in practice as far as you can. Container records are small and the requests arrive unpredictably.

Filed underauditdocumentationtraceabilityfood safety

Written by the Certification Bench at IBC Recycling Services, Cleveland, OH. Published October 14, 2025. Figures quoted are working estimates from our own operation unless stated otherwise; verify anything regulatory against the current rules that apply to you.

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