What 173.25A means in plain language
Overpacks are secondary containers used to protect damaged or leaking hazardous materials packages during transport. When a hazmat package is compromised—cracked, leaking, or otherwise unsafe to move—regulations require it to be placed in an overpack that meets specific structural and labeling standards.
A 173.25A citation means an inspector found that your overpack did not meet those required conditions. This could involve improper construction, inadequate sealing, missing or incorrect labels, or failure to use an overpack when one was necessary. The overpack itself must be capable of containing the hazmat product and preventing exposure to other cargo or the environment.
What our enforcement data actually shows
Across our 13 million+ roadside inspection records, 173.25A is a low-volume violation. We have documented 9 all-time citations for failed overpack conditions, with 6 citations in the last 12 months and 2 in the last 90 days. Most recently, we recorded 3 citations in June 2025, followed by single citations in January, February, and March 2026.
The critical takeaway: none of the 9 citations resulted in an out-of-service order. Our inspection data shows a 0.0% OOS rate for this code. This contrasts sharply with the all-FMCSR average OOS rate of 31.4%, indicating that inspectors are treating overpack failures as correctable documentation or packaging issues rather than immediate safety hazards. Ranked 2,230th out of 3,036 FMCSR codes by citation volume, 173.25A remains rare in enforcement.
Who gets cited most
Our enforcement records show citations concentrated in a small number of states. Texas accounts for 2 citations over the last 180 days with a 0.0% OOS rate, followed by New Mexico with 1 citation and 0.0% OOS rate. The low absolute numbers mean state-level variation is not material.
At the carrier level, our data shows fleets such as Precision NDT LLC (USDOT 4116914) with 2 all-time citations for this violation. Seven other carriers each recorded 1 citation: E F Corporation, Continental Battery Company, Crosscountry Freight Solutions Inc, Greenwood Motor Lines Inc, Kleen Rite Transportation LLC, GTM Transport LLC, and Roofline Inc. The pattern suggests overpack issues are isolated incidents rather than systemic fleet problems.
How severe is this compared to similar codes
Compare 173.25A to other hazardous materials packaging and loading violations:
- 177.834A (General loading/unloading hazmat) has logged 3,954 citations with a 99.2% OOS rate—nearly 440 times more frequent and almost universally resulting in vehicle shutdown.
- 172.502(a)(1) (Placarding general requirements) shows 1,820 citations with an 18.5% OOS rate, indicating that placarding failures are taken more seriously than overpack condition issues but still less severe than general loading violations.
- 172.602(c)(1) (Maintenance/accessibility of Emergency Response information) matches 173.25A exactly at 0.0% OOS rate across 1,464 citations, suggesting both are treated as administrative or easily remedied defects.
The data indicates that overpack failures are among the least enforcement-intensive hazmat violations and almost never trigger roadside removal.
How to avoid it
Our co-occurring citations show that overpack violations sometimes appear alongside placarding issues (172.504A), general loading/unloading problems (177.834A), and ELD record-keeping defects. This suggests inspectors are conducting full hazmat package audits when overpack issues are found. To prevent a 173.25A citation:
- Inspect any damaged hazmat package before transport. If a container shows cracks, leaks, or visible damage, do not move it. Place it in a structurally sound overpack—typically a drum or box certified for hazmat containment—before continuing your route.
- Verify overpack labeling and seals. The overpack must be marked with hazard labels that correspond to the contents inside. Check that all seals are intact and secure; a loose or missing seal defeats the containment purpose.
- Use overpack material appropriate to the hazmat class. Different materials handle different chemical hazards. Steel drums suit corrosive substances; absorbent-lined boxes suit liquids. Consult your shipper or hazmat documentation if uncertain.
- Document the overpack application. Keep records showing when and why an overpack was used. This supports your compliance stance if questioned.
- Pre-trip inspection of all hazmat packaging. Before departing a shipper, examine every hazmat package for cracks, wetness, or deformation. Flag any compromise immediately rather than discovering it at roadside.
Top vehicle makes cited for this violation—Mack and Ford trucks (2 citations each)—suggest no single truck type is at higher risk, pointing to driver and carrier handling practices as the primary factor.