FMCSR 172.338: Missing ID Number on Hazmat—What You Need to Know

No—most likely not. Across our 13 million inspection records, code 172.338 carried an out-of-service rate of 12.5% (2 OOS placements out of 16 all-time citations). That's significantly lower than the 31.4% average OOS rate across all FMCSR codes. However, the possibility exists, so immediate corrective action is critical.

Moderately serious, but less severe than other hazmat placarding failures. Our inspection data shows 172.338 ranks #2026 of 3,036 FMCSR codes by citation volume—it's rare. Compare this to peer violations: 177.834A-HMC (general loading/unloading hazmat) has a 99.2% OOS rate and 3,954 citations; 172.516(c)(6) (placard damaged/obscured) has a 1.6% OOS rate. Your violation sits in the lower-risk tier for hazmat enforcement.

1. Verify the ID number location: Confirm the specific placard or label where the ID was missing.
2. Replace or repair immediately: Install the correct UN/NA identification number if it's removable labeling; replace the placard if it's on a placard.
3. Document the correction: Photograph the repair and keep the receipt or maintenance log.
4. Request a re-inspection (if applicable in your state) to clear the citation.
5. Check your records: Ensure all hazmat packaging and placarding procedures are compliant going forward.

This is a carrier-level violation. The citation reflects the carrier's failure to maintain proper hazmat identification on vehicles or packages in transit. However, it may appear in your CSA Safety Management BASICs if you were operating the vehicle. Both drivers and carriers should review their hazmat compliance procedures to prevent recurrence.

Our records show only 1 citation for code 172.338 in the last 12 months (issued in July 2025), and zero citations in the last 90 days. This is an extremely rare violation. The all-time total since records began is just 16 citations. The rarity suggests it's typically caught during specialized hazmat audits rather than routine roadside inspections.

Yes, you can file a DataQs (SAFER Roadside Data Quality) challenge if you believe the citation was issued in error. Document the following: (1) proof that the ID number was present and visible at the time of inspection, (2) photographs showing compliance, (3) maintenance records. DataQs challenges are reviewed by FMCSA within 30 days. Since this is a documentation/labeling issue (not a safety equipment failure), evidence of the ID number is your strongest argument.

Across our database, ALBERTO VAZQUEZ PEREZ (USDOT 3260169) has the highest citation count at 2 citations. All other carriers cited for 172.338 have 1 citation each. The wide distribution across carriers indicates this isn't a systemic fleet problem—it's sporadic enforcement. Most citations are concentrated in small or regional carriers rather than large national fleets.

Moderate urgency. While the OOS rate (12.5%) is below average and citations are rare, hazmat violations carry federal oversight. Correct the missing ID number before your next inspection. Our data shows 1 citation in the past 12 months, indicating consistent but infrequent enforcement. Don't delay—a second citation could invite closer scrutiny of your entire hazmat compliance program.