FMCSR 172.331(a): ID Numbers for Bulk Hazmat — Q&A

It's possible, but not automatic. Across our inspection records, 172.331(a) citations resulted in an out-of-service placement 60.0% of the time (3 out of 5 all-time citations). That's nearly double the 31.4% average OOS rate across all FMCSR codes. However, 40% of citations for this violation did not result in immediate OOS, meaning the inspector's assessment of the specific compliance gap matters significantly to the outcome.

This violation is rare in enforcement. Our database shows only 5 citations for 172.331(a) in all-time records, ranking it #2406 of 3,036 FMCSR codes by citation volume. In the last 12 months, there were 0 citations, and 0 in the last 90 days. This low volume suggests either excellent industry compliance or infrequent roadside focus on this specific identification requirement.

First, clarify what ID numbers the inspector found missing or incorrect on your hazmat shipping papers or packages. Request the specific citation details in writing from the enforcement officer. Second, contact your carrier's hazmat compliance officer immediately—this citation belongs to your carrier's safety record. Third, review your shipper's documentation (Bill of Lading, hazmat certification) to confirm all required ID numbers were provided. If you believe the citation is inaccurate, initiate a DataQs challenge within 90 days through FMCSA.

172.331(a) is serious but less severe than some peer violations. The most comparable codes—177.834A-HMC and 177.834(a), both covering general loading/unloading of hazmat—show OOS rates of 99.2% and 97.9% respectively, with thousands more citations. Placard-specific violations like 177.817(a) have a 75.1% OOS rate. At 60.0%, your violation sits in the moderate-to-high range, indicating real enforcement risk but not the highest severity tier.

Yes. DataQs allows you to challenge factual or procedural inaccuracies in roadside inspection records. If the inspector cited you for missing ID numbers on hazmat documentation but those numbers were present and legible on your shipping papers, you have grounds for a challenge. Submit supporting evidence—dated photos, signed Bills of Lading, hazmat certification forms—within 90 days of the citation. FMCSA reviews your evidence and either upholds or removes the citation from your record.

Central Transport LLC (USDOT 661173) has the most citations for this violation at 3 all-time records. Profit Express Inc (USDOT 1994530) and Apollos Waters LLC (USDOT 2922489) each have 1 citation. Given the total citation count of only 5 across our entire database of 13 million inspections, these carriers represent isolated enforcement events rather than a pattern requiring systemic intervention.

This violation is a carrier responsibility. The regulation requires the offeror—the person or entity offering hazmat for transport—to provide the motor carrier with proper ID numbers. While a driver may be present during the inspection, the citation reflects the carrier's failure to ensure hazmat packaging and documentation are complete before pickup. The violation appears on the carrier's safety record and CSA profile, not the driver's.

Our records show that HYTR and PTRB vehicle makes each received 3 citations for this violation (all 5 citations combined). These represent the limited sample size: with only 5 total citations in our database, no strong pattern emerges by vehicle type. The violation itself concerns hazmat documentation and packaging identification, not vehicle configuration, so any truck capable of transporting bulk hazmat packages could potentially be cited.