FMCSR 173.35A: Intermediate Bulk Container Requirements Q&A

No. Across our 13 million inspection records, FMCSR 173.35A has never resulted in an out-of-service placement—the OOS rate is 0.0%. All 3 citations ever recorded in our database were issued without removing the vehicle from service. For context, the average FMCSR code carries a 31.4% OOS rate, so this violation is significantly less severe in enforcement terms. However, intermediate bulk container compliance failures still warrant prompt attention to prevent escalation.

173.35A is considerably less severe than most peer violations in the Hazardous Materials category. Our data shows similar codes like General Loading/Unloading Hazmat (177.834A-HMC) carry a 99.2% OOS rate and 3,954 citations, while Placarding Violations (177.817(a)) hit 97.9% OOS with 2,274 citations. By contrast, 173.35A has only 3 all-time citations and 0% OOS rate. This code ranks #2551 out of 3,036 FMCSR codes by enforcement volume, indicating it's rarely cited and treated less strictly than core hazmat transport violations.

No recent enforcement activity. Our records show zero citations of FMCSR 173.35A in the last 12 months and zero in the last 90 days. The only 3 citations we have on record span multiple years. This suggests either strong carrier compliance with intermediate bulk container requirements or low inspection focus on this specific regulation. If you've been cited recently, it may indicate a significant deficiency worth addressing immediately.

First, document the citation details and the exact container deficiency noted by the inspector. Second, review your intermediate bulk container maintenance and labeling procedures—173.35A governs container specifications and conditions. Third, contact your fleet safety manager or compliance officer to determine if this is an isolated incident or a systemic issue. Fourth, correct the cited deficiency before the vehicle is re-loaded with hazardous materials. Finally, request the inspection report from your DOT officer to verify citation accuracy through your carrier's compliance system.

Yes. Any FMCSR citation, including 173.35A, can be contested through the FMCSA's DataQs Roadside Data Review (RDR) process. You or your carrier's safety director can submit a formal challenge within 90 days of citation if you believe the violation was incorrectly documented or if supporting evidence contradicts the finding. Your case is strongest if you have maintenance records, container inspection logs, or photographic evidence proving compliance at the time of the stop. Submit through the FMCSA portal with clear documentation.

Our inspection records show only three carriers have ever received FMCSR 173.35A citations: HYDRO PLUS LLC (USDOT 962896), IMPERATIVE CHEMICAL PARTNERS INC (USDOT 1796904), and CHEMSTATION PHILADELPHIA LTD (USDOT 3328928). Each received 1 citation. This extremely limited citation history reinforces that 173.35A is rarely enforced. If your carrier is listed, review your hazmat transportation compliance program for potential process gaps.

Low urgency from an operational standpoint—the violation won't remove your truck from service and won't trigger immediate CSA scoring penalties comparable to other hazmat codes. However, it should not be ignored. The fact that 173.35A citations are extremely rare (3 all-time, 0 in the last 90 days) means if you received one, an inspector identified a genuine compliance gap. Correct the intermediate bulk container issue before your next hazmat shipment to avoid citation escalation or carrier compliance audit findings.

The single vehicle make cited for FMCSR 173.35A in our records was a FRHT (Freightliner). This data point is from one of only three total citations, so it does not indicate a systematic issue with any particular vehicle class or manufacturer. The rarity of 173.35A citations means compliance problems are not concentrated in any specific equipment type.