FMCSR 172.604: Emergency Response Phone Number – Q&A

No. Across our 13 million inspection records, only 1 out of 255 all-time citations for 172.604 resulted in an out-of-service order—a 0.4% OOS rate. This is significantly below the national average OOS rate of 31.4% across all FMCSR codes. You will almost certainly receive a citation, but your truck will not be removed from service on the spot.

Code 172.604 addresses offering hazardous materials for transportation without the proper emergency response telephone number. Hazmat shipments are required to have a current, accessible emergency contact line in case of an incident. If your paperwork lacks this number or lists an incorrect one, you're cited. It's a documentation violation, not an equipment defect.

This is a rare citation. Our records show 255 all-time citations for 172.604, ranking it #1144 of 3,036 FMCSR codes by volume. In the last 90 days, we recorded only 6 citations nationwide. In the last 12 months, enforcement averaged less than 2 citations per month. If you're cited for this, you're in a small group.

First, verify the emergency response telephone number on your hazmat paperwork and shipping documents. Confirm the number is current, accurate, and belongs to the authorized emergency response contact. Update your records and carrier's systems to reflect the correct number. When co-citations occur, they often involve incomplete hazmat descriptions or placarding issues, so audit those areas too. If you were cited alongside other hazmat violations, address all of them before your next shipment.

172.604 is much less severe than most hazmat citations. Peer codes like general loading/unloading violations (177.834A-HMC) have a 99.2% OOS rate, and placarding violations (177.817A) reach 75.1% OOS. By contrast, 172.604's 0.4% OOS rate puts it near the bottom of severity. It's serious enough to cite, but inspectors treat it as a paperwork fix rather than an imminent safety threat.

Over the last 180 days, Illinois recorded the most citations with 4, followed by Iowa with 1, North Carolina with 1, and New Mexico with 1. Enforcement is geographically sparse. The data shows no state has high citation frequency for this code, suggesting it's caught sporadically during routine hazmat inspections rather than as a targeted enforcement focus.

Citations are sporadic month to month. Our 12-month trend shows peaks in May 2025 (5 citations) and March 2026 (5 citations), with most other months recording 1–2 citations. There's no clear upward or downward trend. The low overall volume and irregular pattern suggest enforcement depends on inspector initiative during routine hazmat checks rather than a coordinated compliance campaign.

Yes, you can file a DataQs rebuttal. Since 172.604 is a documentation issue—the presence and accuracy of an emergency response number—you have solid ground to contest if you can prove the number was correct, current, and properly displayed when cited. Gather your shipping documents, carrier records, and emergency response contact verification from the date of inspection. Document that the information was compliant at the time of the violation.