FMCSR 172.331C: Bulk Packages Without ID Numbers — Q&A

Direct answers about hazmat bulk package ID violations. Will you get put out of service? What happens next? Evidence from 13M+ inspections.

Severity Weight
N/A
OOS Eligible
No
BASIC Category
Hazardous Materials
Code System
FMCSR
Code:
172.331C
Code System:
FMCSR
BASIC Category:
Hazardous Materials
OOS Eligible:
No
Severity Weight:
N/A

Ranks #2,567 of 3,146 FMCSR codes by citation frequency • OOS rate of 0.0% is below the FMCSR-wide average of 33.3%.

Violation Description

Transport other bulk packages without proper ID Numbers

Questions & Answers

Direct answers grounded in TruckCodex inspection data

will 172.331C put my truck out of service

No. Our inspection records show a 0.0% out-of-service rate for 172.331C violations across all-time data. Of the 3 citations issued for this violation, 0 resulted in an out-of-service order. For comparison, the all-FMCSR average OOS rate is 31.4%, making this violation significantly less likely to trigger an immediate roadside shutdown than the typical hazmat citation.

how serious is 172.331C compared to other hazmat violations

This violation ranks #2551 of 3,036 FMCSR codes by citation volume, placing it among the rarest hazmat infractions. Peer violations in the same hazardous materials category show vastly higher enforcement and OOS rates—for example, general loading/unloading hazmat violations (177.834A-HMC) carry a 99.2% OOS rate and 3,954 all-time citations. The 0.0% OOS rate for 172.331C indicates enforcement officers rarely escalate this infraction to an immediate roadside violation.

what should I do immediately after getting cited for 172.331C

First, document the citation details and vehicle information. Second, review your bulk package labeling and identification procedures with your dispatcher or safety manager—ensure all packages are marked with required UN or ORM identification numbers before transport. Third, check your hazmat paperwork and placarding. Our data shows 172.331C sometimes appears with 172.322B (missing MARPOL markings) in the same inspection, so verify all required markings are in place. Finally, contact your carrier's safety department within 24 hours to file a prevention report.

is 172.331C getting cited more often lately

No, citation volume is extremely low and trending flat. Across the last 12 months, only 2 citations were issued for 172.331C. In the last 90 days, only 1 citation appeared in our 13 million+ inspection database. The monthly trend shows sporadic enforcement with 1 citation in December 2025 and 1 in February 2026. This violation is not a common roadside finding.

where do officers cite 172.331C most often

Illinois is the only state in our top-state ranking for 172.331C enforcement in the last 180 days, with 2 citations and a 0.0% OOS rate. Due to the extremely low national citation volume (3 all-time), enforcement is highly localized. If you operate primarily in other regions, you should still comply with the requirement to transport bulk packages with proper ID numbers, but the likelihood of citation varies significantly by route and jurisdiction.

can I contest a 172.331C citation through DataQs

Yes, hazmat citations are contestable through the FMCSA DataQs RDR (Roadside Data Review) process if you have evidence that contradicts the inspector's finding. For 172.331C, contestability depends on whether you can demonstrate the bulk packages were properly identified with the required UN or ORM-D numbers at the time of inspection. Gather photos, shipping manifests, and packaging documentation to support your appeal. The DataQs window typically opens 30 days after citation issuance.

172.331C citation carriers and vehicle types most commonly cited

Our all-time data shows 172.331C citations spread across three carriers: New Prime Inc (USDOT 3706), Ilmo Products Company (USDOT 78802), and Vega Transport LLC (USDOT 1358485), with 1 citation each. Vehicle makes cited include Freightliner (2 citations) and Wabash (2 citations). The low citation count indicates this is not a systemic issue at any single carrier, suggesting isolated compliance lapses rather than fleet-wide deficiencies.

does a 172.331C violation follow the driver or the carrier in CSA

Hazmat violations like 172.331C are tracked in FMCSA's CSA safety profiles for both the driver and the carrier. However, responsibility typically falls on the carrier's safety management, as proper hazmat identification and labeling procedures are established by company policy. Your CSA record will reflect the citation, but your motor carrier's BASIC scores and safety rating will carry more weight in enforcement decisions and audits.

Last updated: 2026-04-20T17:26:35.077Z Answers reference TruckCodex inspection data Read the full article → Fleet FAQ →

Top Enforcing States

Where 172.331C is most commonly cited (last 180 days)

1. Illinois
1
OOS 0.0%

Data sources & freshness

TruckCodex aggregates official public-sector datasets. See the Source registry for dataset-level coverage and the Freshness log for last-import timestamps.

Census, SAFER, SMS, Licensing & Insurance (L&I), roadside inspections, crashes, and authority history.

Refreshed daily.

Vehicle recall campaigns, defect investigations, and consumer safety complaints (SCRS).

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EIA

Retail diesel and gasoline price history and state fuel-tax tables.

Refreshed weekly.

Cross-border carrier registry and Canadian recall campaigns where applicable.

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TruckCodex is an independent aggregator; it is not affiliated with FMCSA, NHTSA, EIA, or Transport Canada. Always verify compliance-critical information directly with the originating agency.