What 172.322(b) means in plain language
FMCSR 172.322(b) requires that bulk packaging used to transport certain hazardous materials must display proper MARPOL markings. MARPOL stands for the International Convention for the Prevention of Pollution from Ships—a set of international maritime standards that also apply to some land-based hazmat transport operations.
In practical terms, if you're hauling hazardous materials in bulk containers, those containers must be clearly marked according to MARPOL specifications. These markings tell inspectors, emergency responders, and other parties that the package meets international pollution-prevention standards for the cargo inside. A citation for this violation means an inspector found that your bulk packaging was missing these required markings, or the markings were illegible, incomplete, or improperly applied.
This is a documentation and labeling issue—not a mechanical or safety defect of the vehicle itself. It's about ensuring hazmat containers are properly identified for regulatory compliance and emergency response purposes.
What our enforcement data actually shows
Across our 13 million+ inspection records, 172.322(b) citations are extremely rare. We have recorded 12 all-time citations for this violation. In the last 12 months, we saw 0 citations, and in the last 90 days, we recorded 0 citations as well. This code ranks #2132 of 3,036 FMCSR codes by citation volume.
The out-of-service rate for 172.322(b) is 0.0%—meaning none of the 12 citations resulted in the vehicle being placed out of service. This stands in sharp contrast to the all-FMCSR average out-of-service rate of 31.4%. In other words, inspectors consistently issued citations for this violation without removing the vehicle from operation, which suggests they viewed the violation as correctable or non-critical to immediate roadside safety.
The rarity of citations for this specific code indicates that bulk packaging MARPOL markings are either being applied correctly by most carriers or are not a high-priority focus area for roadside enforcement relative to other hazmat violations.
Who gets cited most
Our inspection database does not include state-level breakdown for this violation, so we cannot identify which states are enforcing it most frequently. However, we can point to carrier-level patterns.
Our data shows fleets such as SILVICOM INC (USDOT 1864495) and S & M TRUCKING LTD (USDOT 299953) with 2 citations each in our all-time records for 172.322(b). TREATMENT TECHNOLOGY HOLDING LLC (USDOT 3869323) also appears with 2 citations. These carriers represent the only fleets in our dataset with multiple citations for this violation. The presence of these companies does not imply systematic negligence—all three received citations without being placed out of service, consistent with the overall 0.0% OOS rate for this code.
How severe is this compared to similar codes
Within the Hazardous Materials category, 172.322(b) sits at the milder end of the enforcement spectrum when compared to peer violations.
For example, 177.834A-HMC (General loading/unloading hazmat violations) generated 3,954 citations with a 99.2% out-of-service rate—a fundamentally different enforcement profile. Similarly, 177.817(a) (Placarding violation) saw 2,274 citations with a 75.1% OOS rate. Both of these codes are cited far more frequently and result in vehicle impoundment at roadside the vast majority of the time.
A closer peer in terms of enforcement severity is 172.516(c)(6) (Placard damaged, deteriorated, or obscured), which has 1,796 citations and a 1.6% OOS rate—very similar to 172.322(b)'s profile. This suggests that missing or defective markings on packaging are treated more leniently by inspectors than active loading/unloading violations or missing placards entirely.
How to avoid it
Since this violation centers entirely on proper marking of bulk hazmat packaging, the prevention strategy is straightforward:
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Verify MARPOL markings before accepting cargo. During your pre-trip inspection, examine all bulk packaging. Ensure markings are present, legible, and match the hazmat commodity being transported. If any marking is faded, missing, or unclear, refuse the load or request that the shipper correct it before departure.
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Know what MARPOL markings look like for your cargo type. Work with your dispatcher or safety department to understand which hazmat commodities in your company's typical loads require MARPOL markings. Ask for training or a reference guide so you can spot missing or incorrect markings on sight.
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Check container condition at loading. Before bulk packaging is loaded onto your vehicle, visually inspect the exterior. Markings can be obscured by dirt, corrosion, or physical damage. If you suspect a marking is hidden or damaged, ask the loader to clean or repair the container surface so markings are visible and compliant.
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Document the condition of markings. Take photos of bulk packaging markings as part of your pre-trip documentation. This creates a record that you accepted the load with compliant markings and protects you if a marking deteriorates during transport without your knowledge.
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Report and correct immediately if you discover missing markings en route. If you discover during a roadside stop or weigh station that a bulk container is missing MARPOL markings, contact your dispatcher and hazmat shipper immediately. The violation is correctable and does not typically result in an out-of-service order, so swift corrective action—such as having the shipper apply proper markings at the next facility—resolves the issue.