172.604(a) ER Telephone Not As Required – Citations & OOS Rate

No. Our inspection records show a 0.0% out-of-service rate for 172.604(a) citations across all-time data. This violation is not eligible for immediate out-of-service placement. While this code is significantly less severe than peer hazmat violations—for example, general loading/unloading hazmat violations (177.834A-HMC) carry a 99.2% OOS rate—you still need to correct the violation promptly. The absence of OOS placement means you can typically continue operations while addressing the deficiency.

This is among the least severe hazmat violations. Across 13 million inspections, the national average out-of-service rate is 31.4%. By contrast, 172.604(a) has a 0.0% OOS rate, placing it far below peer codes in the same hazmat category. For comparison, placarding violations (177.817(a)) reach 75.1% OOS rates, and general loading/unloading hazmat violations (177.834(a)) hit 97.9%. This code targets documentation and communication rather than active safety hazards, which explains the minimal enforcement frequency and zero out-of-service outcomes.

Immediate steps:

1. Get the citation details – Review the exact deficiency noted by the inspector (emergency response information access/clarity).
2. Contact your carrier's safety department – They may have procedures for hazmat compliance correction.
3. Verify current emergency response procedures – Ensure your vehicle documentation meets the requirement.
4. Document the correction – Keep proof that you've addressed the issue.
5. Request re-inspection if needed – Some carriers follow up to confirm compliance.

Our data shows this violation is extremely rare—only 1 citation all-time—so your corrective steps are straightforward and low-risk.

No. The citation rate for 172.604(a) is exceptionally low and stable. Our database shows 1 all-time citation, 0 citations in the last 12 months, and 0 in the last 90 days. This code ranks #2796 out of 3,036 FMCSR codes by citation volume. The extreme rarity suggests either widespread carrier compliance, minimal inspector focus on this specific requirement, or both. If cited, you're in an uncommon situation—but the low enforcement frequency also means corrective guidance is straightforward.

Werner Enterprises Inc (USDOT 53467) received the single 172.604(a) citation in our records. That violation involved an International truck. The one-off nature of this citation underscores how rarely this violation appears in roadside enforcement. If your carrier or fleet is different, this data point suggests your operation likely has proper emergency response procedures in place. Werner's citation offers no broader pattern—it represents an isolated compliance gap, not a systematic issue across the industry.

Yes, you can challenge the citation through the FMCSA's DataQs (Dispute Resolution) process. DataQs allows drivers and carriers to submit evidence that a violation was recorded incorrectly, that the inspection was invalid, or that the violation does not apply to your operation. For 172.604(a)—a documentation-based violation—you would need to demonstrate that your emergency response procedures were correct and visible to inspectors at the time of the roadside stop. Documentation corrections are generally easier to contest than equipment failures. File your challenge within 90 days of the citation for the strongest position.

This is low-urgency from an out-of-service perspective, but compliance is still required. Our data shows zero out-of-service placements for this code, and citation frequency is extremely rare (1 all-time, 0 in the last 12 months). However, hazmat regulations exist for public safety—your emergency response information must be accessible and current. Correct the deficiency within a reasonable timeframe (typically 1–2 weeks), verify with your carrier's safety team, and document the fix. The low enforcement pressure does not exempt you from compliance; it simply means inspectors rarely examine this specific requirement.

This violation affects both you and your carrier in FMCSA CSA (Crash Safety Analysis) records. Roadside inspection violations are recorded against the driver's record and the carrier's record simultaneously. If you were operating under dispatch or explicit company procedures, your carrier may share responsibility. CSA severity determines whether points appear in the driver qualification or hazmat safety BASICs. Given the low enforcement volume and 0.0% OOS rate, this violation will have minimal impact on either record, but it remains part of your official inspection history. Request a copy of the citation to confirm all details are accurate.