FMCSR 172.302(c): No Special Permit Number on Bulk Package

Probably not. Across our inspection records, only 1 out of 5 all-time citations for this code resulted in an out-of-service placement—a 20.0% OOS rate. This is substantially lower than the 31.4% average OOS rate across all FMCSR codes, and far below peer hazmat violations like general loading/unloading infractions that carry 97.9% to 99.2% OOS rates. However, OOS eligibility depends on the specific circumstances of your inspection, so review the inspector's narrative on your citation.

It's one of the less-enforced hazmat infractions. This code ranks #2406 of 3,036 FMCSR codes by citation volume—our database shows only 5 all-time citations. Compare that to peer hazmat codes: general loading/unloading violations (177.834a-HMC) total 3,954 citations, and placard-related violations (177.817(a)) hit 2,274. The low citation count and below-average OOS rate suggest this is enforced selectively, typically where paperwork deficiencies are glaring rather than structural hazmat safety failures.

Immediate steps: (1) Obtain a copy of your full inspection report from your carrier or the FMCSA Portal. (2) Verify the specific bulk package in question and confirm whether a special permit number should have been present. (3) Contact your hazmat compliance officer or safety manager—this is a documentation issue, not necessarily an equipment defect. (4) Preserve all paperwork related to that shipment for potential DataQs review. (5) Do not move hazmat loads until you understand whether this citation affects your current authorization.

Yes, contestation is possible. Since this violation relates to paperwork and permit documentation rather than vehicle condition or driver behavior, it may be eligible for DataQs review if you can demonstrate the permit number was actually present, properly recorded, or not required for that specific shipment. DataQs allows carriers and drivers to challenge factual roadside inspection findings within 90 days of the inspection. Submit evidence (bill of lading, shipping papers, permit documentation) directly through the FMCSA DataQs portal. Success depends on documentation quality, not inspector opinion.

CSA point values are not published by FMCSA by individual code. The violation will be recorded in the Hazardous Materials Safety BASIC, where it contributes to your carrier's percentile ranking. Because our inspection data shows no out-of-service placements in the last 90 days for this code, and only 1 OOS decision out of 5 all-time, the infraction is likely weighted lower than critical hazmat violations. To learn your specific point impact, check your carrier's safety scorecard or the FMCSA Safety Management Cycle for your company's Hazardous Materials percentile.

Enforcement is extremely rare. Our database records zero citations for this code in the last 90 days and zero in the last 12 months, despite 5 all-time citations in our 13 million+ inspection records. This suggests either the violation has become rarer among carriers (improved compliance) or inspectors are deprioritizing it. Regardless, the regulation remains in force—bulk hazmat shipments without proper permit numbers are still violations. Treat this as a low-frequency but real compliance requirement, not an obsolete rule.

Five carriers, one citation each. Our records show NUCO2 SUPPLY LLC (USDOT 578807), HOBBS RENTAL LLC (USDOT 2053622), WESTERN TRANSPORT LOGISTICS INC (USDOT 2263801), KEMIRA WATER SOLUTIONS INC (USDOT 2769721), and TDR DEVELOPMENT INC (USDOT 2808170) each received one citation for this code. The single-citation pattern across all carriers suggests this is not a systemic compliance weak point for any one company, but rather an isolated documentation oversight in hazmat operations.

Both. The citation is issued to the vehicle and carrier, and it lands in your company's Hazardous Materials Safety BASIC, affecting fleet-wide percentiles and CSA ratings. As the driver, it may also appear on your record depending on whether you were the operator and whether your carrier reports it to your file. The regulation itself is a carrier responsibility—proper permit documentation should be verified before dispatch—but drivers who knowingly operate without required permit numbers share liability. Clarify with your safety manager whether this citation will be linked to your personal driving record.