FMCSR 172.330(c): NON-ODORIZED LPG Tank Car Citations

No. Across our 13 million+ inspection records, this violation has resulted in zero out-of-service placements in all-time data. The OOS rate for 172.330(c) is 0.0%—both citations on record were allowed to continue operating. This is substantially lower than the 31.4% average OOS rate across all FMCSR codes, making this one of the least severe hazmat citations issued at roadside.

Much less serious than related hazmat codes. Our inspection records show 172.330(c) carries a 0.0% out-of-service rate, while similar hazmat violations in the same category range from 1.6% to 99.2% OOS rates. For comparison, general loading/unloading hazmat violations (177.834A-HMC) are placed out of service in 99.2% of cases, and placarding violations (177.817(a)) in 75.1% of cases. The rarity of enforcement—only 2 citations all-time—also indicates this rule is infrequently violated.

Extremely rarely. Across 13 million+ inspections in our database, this code ranks #2651 out of 3,036 FMCSR codes by citation volume. Only 2 citations exist in our all-time records, with 0 citations in the last 12 months and 0 in the last 90 days. This low enforcement volume suggests the violation is either uncommon or rarely detected at roadside inspections.

First, review the inspection report for the specific finding. Second, verify your tank car's odorization status with your carrier or maintenance team—this code addresses whether non-odorized LPG was improperly marked or transported. Third, request a copy of the inspection from your carrier and consult your hazmat documentation. Fourth, if you believe the citation is incorrect, you may contest it through the FMCSA DataQs (Databse Quality System) within 90 days of issuance by submitting documentation that proves compliance. Work with your fleet safety manager to correct any record-keeping gaps.

This violation falls within the Hazardous Materials BASIC category of the FMCSA's Compliance, Safety, Accountability (CSA) program. Citations in this category contribute to your carrier's hazmat BASIC score, which influences your Safety Management Cycle. However, the exact CSA point value depends on severity weighting applied by FMCSA at the time of citation. With an OOS rate of 0.0%, this code typically carries lower severity than related hazmat violations, so the CSA impact is generally minimal compared to high-OOS-rate codes.

Our inspection records show two carriers cited for this violation: California Gas Transport Inc (USDOT 589266) with 1 citation, and Bobadilla Trucking Inc (USDOT 3718455) with 1 citation. Given the extremely low citation volume—only 2 all-time—this does not indicate a pattern or systemic problem at either carrier. The rarity of enforcement means most carriers operating LPG tank cars remain citation-free for this specific rule.

Low to moderate urgency from an operational standpoint, since the OOS rate is 0.0%—no immediate removal from service is expected. However, you should address the compliance gap promptly to avoid repeat citations and CSA score accumulation. Work with your carrier's hazmat compliance team to verify tank car odorization status and correct any marking or documentation errors. Given zero citations in the last 90 days, this rule is not a current enforcement priority, but remaining compliant protects your safety record.

Yes. If you believe the citation is factually incorrect, you may file a challenge through the FMCSA's DataQs (Database Quality System) within 90 days of the inspection date. DataQs is designed for drivers and carriers to dispute roadside inspection findings when documentation or evidence contradicts the citation. Since 172.330(c) involves tank car marking and LPG odorization status—checkable facts—you can submit proof of compliance. Contact your carrier's safety manager for help gathering documentation and filing the dispute through the FMCSA website.