FMCSR 172.322B: No MARPOL Marking on Bulk Packaging

No. Across our inspection records, 172.322B has never resulted in an out-of-service citation. The OOS rate is 0.0% across all 4 citations in our database. This is significantly lower than the national average OOS rate of 31.4% across all FMCSR codes, and far below peer hazmat violations like general loading/unloading violations (99.2% OOS rate) or placard deterioration issues (5.2% OOS rate). You will not be ordered off the road for this citation.

First, document the exact location and condition of the bulk packaging in question. Check whether other hazmat compliance issues were cited in the same inspection—our data shows 172.322B often appears alongside missing hazmat class/division ID numbers (172.332A), damaged placards (177.817E), and various mechanical defects. Notify your dispatcher and safety manager of the citation. Request copies of the inspection report and photos. Do not operate that vehicle for hazmat transport until the MARPOL marking issue is corrected and documented. Contact your carrier's compliance officer to verify proper remediation steps.

172.322B is a lower-severity hazmat citation. It ranks #2480 out of 3,036 FMCSR codes by citation volume—meaning it is cited very infrequently. Our records show only 4 all-time citations and 0 out-of-service placements. Compare this to common hazmat peer violations: general loading/unloading violations (3,954–3,839 citations, 97–99% OOS rates), placard violations (2,274 citations, 75% OOS rate), and placard deterioration (2,038 citations, 5.2% OOS rate). 172.322B is substantially less common and carries no automatic out-of-service consequence.

In the last 180 days, 172.322B citations have occurred in two states: Texas (2 citations) and Illinois (1 citation). Both Texas citations resulted in no out-of-service placement. The citation is rare nationally—only 3 citations in the last 12 months—so geographic clustering reflects low absolute volume rather than a systematic enforcement pattern.

The citation remains very rare. Our inspection records show 3 citations in the last 90 days and 3 in the last 12 months, with all 3 recent citations occurring in February 2026. This represents consistent but minimal enforcement activity. The fact that only 4 total citations exist in our 13 million-record database suggests this violation is either inherently uncommon or primarily addressed through other regulatory pathways.

Yes. FMCSA's DataQs (Driver Records and Roadside Inspection Query System) allows you to contest any roadside inspection record, including 172.322B citations. You have 90 days from the inspection date to submit a challenge. Since 172.322B is a documentation/marking issue rather than an on-the-spot equipment defect, you can contest it if: the bulk packaging actually carried proper MARPOL marking that the inspector missed, the marking was legible but misread, or the vehicle or load type did not require MARPOL marking under the circumstances. Gather photos, shipping documents, and packaging records to support your appeal.

Our all-time citation data shows 172.322B distributed across four carriers: New Prime Inc, North American Bulk Transport Inc, Southern Energy Transportation Inc, and A&A Benitez Trucking LLC. Each carrier has exactly 1 citation on record. The small sample size reflects the rarity of this violation overall. If you drive for one of these carriers, verify that your company has updated bulk packaging marking procedures since the citation was issued.

Hazmat violations like 172.322B are typically assigned to the carrier's safety record and CSA scores, not the driver's personal CSA profile. However, if you were the operator of the vehicle at the time of inspection, the violation may appear in your pre-employment screening (PSP) record. The citation affects your carrier's Hazardous Materials BASIC score and safety profile. If you switch carriers, the violation stays with the previous carrier's USDOT record, not with you personally.