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Industry · September 18, 2020

What the 1989 Recall Quietly Taught the Industry

A 1989 contamination recall changed how the IBC industry thinks about resin sourcing. Most current buyers have never heard the story.

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Mike Tarsis
7 min read · September 18, 2020

There was a contamination recall in 1989 that almost nobody under fifty in the food packaging industry has heard of. It's worth knowing because it shaped almost every regulation and informal practice in our industry for the next thirty years.

What happened

A regional bottled-water producer pulled approximately 2.4 million bottles off shelves in mid-1989 after a downstream lab analysis detected trace levels of contamination. The contamination didn't pose a health risk at the levels found, but the regulatory landscape of 1989 was less forgiving than 2024's. The recall was launched preemptively.

The investigation traced the contamination to a specific lot of HDPE resin used in the IBC totes that staged water between the source spring and the bottling line. The resin lot had been blended from multiple sub-lots, one of which had been improperly recycled material with trace contaminants the producer hadn't been disclosed.

What changed

Three things, immediately:

  1. FDA tightened its resin sourcing requirements for food-contact containers. Single-source virgin HDPE became the default expectation. The era of "anywhere FDA-grade" ended.
  2. The IBC manufacturers had to certify their resin sources downstream of the resin producer. A new layer of documentation was added.
  3. Buyers' spec sheets began requiring "virgin HDPE only" as a defensive clause. This was the spec sheet I wrote about a few months ago — the one that survived in some buyer documents until 2022 without being re-evaluated.

What changed slower

The reconditioning industry didn't really exist in 1989 in the form it does today. As a result, the regulatory architecture that emerged from 1989 implicitly assumed that "used totes" meant "not safe for food" — because there was no formal industry capable of asserting otherwise.

By the mid-2000s the reconditioning industry had matured enough to make a credible food-grade claim, but the FDA hadn't yet updated its informal guidance. The result was a 15-year gap during which reconditioned food-grade totes were physically safe but regulatorily ambiguous.

What I think we should learn from this

Two lessons:

  1. A single contamination event can shape an industry's defensive posture for thirty years. The defensive posture often outlives the cause. Spec sheets should sunset.
  2. The regulatory framework lags the operational reality by 10–20 years. When you're trying to make a decision today, look at what's actually feasible operationally, not what the spec sheet from 1995 says is required.

The FDA's 2021 draft guidance on reconditioned food-contact containers is, in effect, the regulatory catching up to the operational reality. We've been doing chain-of-custody for over a decade. The FDA noticed.

History matters in this industry. The reason your spec sheet says "virgin only" probably traces back to a recall you've never heard of. Look up your history before writing your future.
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