What 172.330(c) means in plain language
This regulation requires that liquefied petroleum gas (LPG) transported in tank cars must have a properly documented non-odorized entry if the cargo being hauled is non-odorized LPG. The rule exists because LPG is naturally odorless, making it a safety hazard—people cannot smell a leak. To address this, regulations mandate that either the gas itself is odorized (has an odorant added), or the documentation clearly reflects that non-odorized product is aboard.
When you transport LPG in a tank car, your paperwork must accurately match what's inside. If your tank contains non-odorized LPG, your shipping papers, placards, and tank markings must all show that designation. A citation under 172.330(c) means an inspector found a mismatch: your documentation failed to include or properly record the non-odorized status for LPG cargo in a tank car.
What our enforcement data actually shows
Across our 13 million roadside inspection records, 172.330(c) citations are extremely rare. We see only 2 all-time citations in our database, with 0 citations in the last 12 months and 0 in the last 90 days. This code ranks #2651 of 3,036 FMCSR codes by citation volume—among the least-cited regulations in hazardous materials transport.
None of the 2 citations on record resulted in an out-of-service order. The out-of-service rate for this code is 0.0%, compared to an all-FMCSR average of 31.4%. This does not mean the violation is unimportant; rather, it reflects that inspectors rarely encounter documentation errors of this specific type. When they do, the citation typically stands as a correctable defect rather than an immediate safety removal.
Who gets cited most
Our data shows only two carriers with citations under this code, each with one citation: California Gas Transport Inc (USDOT 589266) and Bobadilla Trucking Inc (USDOT 3718455). The vehicles cited were a Kenworth (KW) and a Lubbock (LUBB) truck. With a total citation count of 2 across our entire database spanning multiple years, geographic and carrier patterns are not statistically meaningful. This regulation is enforced so infrequently that no clear hotspot emerges.
How severe is this compared to similar codes
In the hazardous materials category, this code sits far below the enforcement intensity of other LPG and placard violations. For example:
- 177.834A-HMC (General loading/unloading hazmat) has 3,954 citations with a 99.2% out-of-service rate—indicating systematic, safety-critical violations.
- 177.817(a) (Placarding violation) has 2,274 citations with a 75.1% out-of-service rate—showing that when placards are missing or wrong, vehicles typically come off the road immediately.
- 172.502(a)(1) (Placarding general requirements) has 1,820 citations with an 18.5% out-of-service rate—a mid-range severity for documentation errors.
The 0.0% out-of-service rate for 172.330(c) puts it closer to 172.602(c)(1) (Maintenance/accessibility of Emergency Response information, also 0.0% OOS rate) and 172.516(c)(6) (Placard damaged deteriorated or obscured, 1.6% OOS rate). These are paperwork and marking defects that officers cite but rarely use as grounds for vehicle removal, because they do not directly prevent safe transport if corrected before departure.
How to avoid it
Before you load or accept a load:
- Verify the bill of lading and shipping papers explicitly state whether the LPG is odorized or non-odorized. Do not assume; confirm in writing.
- Cross-check the cargo description on your shipping documents against the actual product being loaded into the tank car. If you see "non-odorized LPG" on the manifest, ensure that language appears on your trip paperwork, placards, and any required hazmat documentation.
- If dispatched to pick up or deliver LPG, ask the shipper or receiver to confirm odorization status before you leave the facility. A five-minute conversation prevents a roadside citation.
During your pre-trip inspection:
- Review all hazardous materials paperwork for accuracy and completeness. Specifically check that the product description on shipping papers matches the tank car marking and your understanding of the load.
- For LPG loads, scan your documents for the words "odorized" or "non-odorized." If the status is unclear, stop and contact dispatch or the shipper for clarification.
- Confirm that all placards on the tank car are present, legible, and match the cargo description in your paperwork. Mismatched or missing placards invite detailed inspection, which is when documentation gaps are caught.
In the event of a citation:
If you are cited for 172.330(c), understand that you are not facing an immediate out-of-service order based on our enforcement data. However, the citation will appear on your motor carrier's safety profile and may affect CSA scores. Work with your fleet to correct the underlying documentation issue—typically adding or clarifying the odorization status in your shipping papers—before your next hazmat load.