FMCSR 172.331-HMM: Bulk Package ID Numbers — Driver Q&A

No. Across our 13 million inspection records, this citation has never resulted in an out-of-service order—our data shows a 0.0% OOS rate for 172.331-HMM. This is dramatically lower than the all-FMCSR average of 31.4%, meaning enforcement officers are citing the violation but not stopping your vehicle. However, the absence of an immediate OOS order does not mean non-compliance is trivial; hazmat marking failures still carry regulatory weight and should be corrected promptly.

It is less severe than many peer hazmat codes, but still important. Our records show 172.331-HMM has been cited only 5 times all-time and ranked #2406 out of 3,036 FMCSR codes by volume. Compare that to similar hazmat violations: general loading/unloading failures (177.834A-HMC) trigger an OOS order in 99.2% of inspections, and placard violations (177.817a) carry a 75.1% OOS rate. The marking defect you were cited for is treated as a compliance documentation gap rather than an immediate safety shutdown.

First, verify which bulk package(s) lack the required ID numbers and affix them to comply with DOT hazmat marking rules. Second, photograph the corrected packages for your records—this documentation supports any future DataQs challenge if the citation was issued in error. Third, review your next shipments to ensure ID numbers are in place before loading. Our inspection data shows that 172.331-HMM citations frequently co-occur with labeling violations (172.400A2-HML and 172.406C-HML), so double-check that all hazmat package labels and placards are also complete and properly displayed.

Yes. The DataQs (Roadside Data Quality Inquiry System) process allows you to challenge safety inspection findings that you believe are inaccurate. For marking violations like 172.331-HMM, contestability depends on documentation: if you can provide proof that ID numbers were affixed at the time of inspection, or that the marking standard was met, FMCSA will review your submission. Submit your challenge within the required window (typically within a specified timeframe after citation) through your carrier's CSA portal or directly if you operate independently. Success rates vary, but having photographic or dispatch records strengthens your case.

Our 180-day inspection records show Colorado as the only state with a 172.331-HMM citation in recent months—1 citation logged with a 0.0% OOS rate. The extremely low citation volume (1 in the last 90 days, 3 in the last 12 months, 5 all-time) means this violation is not concentrated in any particular region. Compliance with hazmat ID marking requirements is relatively uniform across the country, or this specific defect is rarely caught during routine inspections.

Enforcement is sporadic but stable. Our 12-month trend shows citations in June 2025 (1), July 2025 (1), and March 2026 (1)—no clear uptick or decline. With only 3 citations in the last year out of 13 million total inspections, this violation represents a tiny fraction of hazmat enforcement activity. Fleet safety managers should treat ID number affixing as part of standard hazmat pre-load verification, but the data does not suggest a widespread crackdown on this specific marking defect.

Inspections citing 172.331-HMM frequently included additional violations. Our records show co-occurring citations for hazmat labeling defects (172.400A2-HML, 172.406C-HML), movement of damaged packages (177.823A-HMTVMNID), and equipment problems like inoperable lamps (393.9A), coupling device defects (393.55D2-B, 393.55E-B), and unsecured emergency equipment (393.95A4-EEUS). This pattern suggests that trucks cited for marking failures may have broader compliance gaps. Conduct a full vehicle and cargo inspection, not just ID number correction.

Our all-time data shows Freightliner and Wabash trailers were cited twice each for 172.331-HMM, with Ford, Peterbilt, and unknown/unpublished makes cited once each. The small sample size (5 citations total) means no vehicle type is disproportionately cited for this violation. Marking defects are not a make-specific issue; they reflect driver preparation and cargo handling procedures rather than equipment design.