FMCSR 172.302A: No ID# on Bulk Packaging — Q&A

Yes, there is a significant risk. Across 13 million inspections in our database, 172.302A citations resulted in an out-of-service order 58.3% of the time. That's nearly double the all-FMCSR average OOS rate of 31.4%, making this violation a serious stop-and-fix issue. Of the 36 all-time citations on record, 21 vehicles were placed out of service and 15 were not.

Moderately serious, but not the most severe. Our inspection records show 172.302A has a 58.3% OOS rate—higher than general placarding violations like 172.502(a)(1) at 18.5%, but significantly lower than major loading violations like 177.834A-HMC at 99.2% OOS. It ranks #1727 out of 3,036 FMCSR codes by citation volume, indicating it is uncommon but carries real enforcement teeth when cited.

Texas dominates. In the last 180 days, our database shows 6 citations in Texas, with 5 resulting in out-of-service orders (83.3% OOS rate). This is notably higher than the national 58.3% rate for this code. If you haul bulk hazmat in Texas, careful ID# marking on packaging is critical to avoid inspection liability.

First, do not move the vehicle if it was placed out of service. Second, inspect all bulk packaging for proper identification numbers and ensure they match shipping documents. Third, review co-occurring violations found in the same inspection—across the last 90 days, inspectors have paired 172.302A with placard placement issues (172.406A1), placard condition problems (172.516C6), and general placarding violations (177.817A and 177.817E). Correct all identified defects before returning to service.

Only once in the last 90 days. However, the trend is rising: over the last 12 months, our inspection records show 16 citations, with a notable spike in September–October 2025 (3 and 4 citations respectively). This suggests increased enforcement focus. If you handle bulk hazmat, now is the time to audit your ID# compliance before citations spike further in your region.

Darkhorse Energy Services LLC (USDOT 3356502) has the highest count with 2 citations. Nine other carriers have 1 citation each across all-time records. The repeat citation on Darkhorse indicates this is a carrier-level compliance issue, not a one-time driver error. Carriers with bulk hazmat operations should implement pre-trip audits to catch ID# marking defects before roadside inspection.

Yes, DataQs allows drivers and carriers to challenge inspection findings on roadside inspection records. A 172.302A citation is generally contestable if the packaging actually did have a proper ID# that the inspector missed or misread, or if the identification was obscured during transport but fully compliant at loading. You have the burden of proof—documentation photos or maintenance records help. Contact FMCSA's DataQs portal with supporting evidence within the applicable timeframe.

Freightliners lead by far: 8 citations across all-time records. Followed by other/unmarked vehicles (6), Kenworth (5), Peterbilt (5), Ford (3), and smaller counts for Chevrolet, Polar, International, Loadstar, and Brenntag. The concentration in Class 8 OTR tractors reflects hazmat bulk transport patterns. Regardless of make, the defect is in shipper/loader marking, not vehicle brand—so compliance depends on your hazmat operation procedures, not your truck.