What 173.35A means in plain language
FMCSR 173.35A governs the proper use and handling of intermediate bulk containers (IBCs) when transporting hazardous materials. These containers—which typically hold between 119 and 793 gallons of liquid or solid hazmat—must meet specific design, construction, and operational standards to ensure safe transport on public roads.
When you're hauling hazmat in intermediate bulk containers, federal regulators require that your containers meet certification and performance specifications. This includes proper markings, structural integrity, and secure positioning within your vehicle. The regulation exists to prevent spills, leaks, and contamination during transit that could endanger public safety.
If you've been cited for 173.35A, an inspector found that your intermediate bulk container or the way you were using it didn't comply with these federal standards. This could range from a container lacking proper documentation to improper securing or handling practices.
What our enforcement data actually shows
Across our database of 13 million roadside inspections, 173.35A is exceptionally rare. Our records show only 3 all-time citations for this code, with 0 citations in the last 12 months and 0 in the last 90 days. This code ranks #2551 out of 3,036 FMCSR codes by citation volume.
No vehicle cited under 173.35A was placed out of service, giving this code a 0.0% out-of-service rate. This is substantially lower than the all-FMCSR average OOS rate of 31.4%, meaning inspectors have not found violations serious enough to immediately sideline trucks on the roadside. However, the extremely low citation count means this enforcement metric carries limited statistical weight.
The rarity of 173.35A citations suggests either strong industry compliance with intermediate bulk container standards or infrequent inspection focus on this specific requirement. Either way, if you received this citation, you're in a small group.
Who gets cited most
Our inspection records show three carriers with citations under 173.35A: Hydro Plus LLC (USDOT 962896), Imperative Chemical Partners Inc (USDOT 1796904), and Chemstation Philadelphia Ltd (USDOT 3328928), each with 1 citation. No state data shows concentrated enforcement patterns due to the minimal citation volume.
The vehicle make cited was a Freightliner (FRHT), a common heavy-duty chassis used in hazmat transport. This single data point does not establish a pattern, but it reflects that intermediate bulk container violations can occur across standard commercial truck platforms.
How severe is this compared to similar codes
Hazmat loading and unloading violations dominate the hazardous materials category. Our data shows that 177.834A (General loading/unloading hazmat) has 3,954 citations with a 99.2% out-of-service rate, and 177.834(a) has 3,839 citations with a 97.9% OOS rate—far more enforcement-heavy and far more likely to result in roadside removal.
Placarding violations tell a similar story: 177.817(a) (Placarding violation) has 2,274 citations at 75.1% OOS rate, while 172.502(a)(1) (Placarding general requirements) shows 1,820 citations at 18.5% OOS rate. By contrast, 173.35A sits at the bottom of enforcement frequency for its category, suggesting regulators either see strong compliance or prioritize other hazmat violations more heavily.
The 0.0% OOS rate for 173.35A also differs sharply from codes like 177.823(a) (Movement of damaged hazmat packages) at 51.8% OOS rate. Inspectors appear to view 173.35A infractions as correctable without immediate vehicle removal, which may reflect the nature of the violations cited.
How to avoid it
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Verify container certification and markings before loading. Check that your intermediate bulk container displays all required DOT markings, capacity labels, and hazmat class placards. Inspect for legibility and proper placement. A certified container is your first line of compliance.
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Inspect the physical condition of the container. Look for dents, cracks, leaks, or corrosion that could compromise containment. Intermediate bulk containers must maintain structural integrity throughout transport. Document the condition in your pre-trip inspection log.
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Secure the container properly in your vehicle. Ensure the IBC is braced or strapped to prevent shifting during acceleration, braking, or turns. Improper securing can lead to tipping, damage, or spillage—all 173.35A violations.
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Confirm container contents match the documentation. Hazmat shipping papers must accurately describe what's in the intermediate bulk container. Misclassified or undeclared materials invite citations.
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Know the specific requirements for your container type. Different intermediate bulk containers have different design and use restrictions. Review the hazmat regulations or your carrier's procedures for the particular container you're transporting; don't assume all IBCs are handled the same way.