In response to public comments, we made some changes to the draft standards. It is prohibited for IBC totes to be brought into an already CNG-certified operation. However, recognizing that many start-ups use IBC totes, the revised standards will allow IBC totes to be grandfathered in to CNG operations, but ONLY IF a) they were in use by that operation prior to certification, and b) they were either purchased new or it can be verified that they were only used for food-grade purposes prior to use by the aquaponics operation. It is expected that the grandfathered IBC totes will eventually be replaced. CNG has prohibited the introduction of IBC totes to a CNG aquaponics operation because they are designed for a one-way trip, not continuous use, so they are subject to degradation – just like water bottles and milk jugs – and shouldn’t be relied upon for long-term use in a commercial aquaponics operation where food is being produced for sale to others.