What 173.36 means in plain language
FMCSR 173.36 covers the general requirements for handling and transporting large bulk packages. These are oversized hazardous materials containers that don't fit standard shipping classifications. The regulation ensures that bulk packages are properly prepared, labeled, and documented before they leave your facility or terminal.
In practical terms: if you're hauling a large bulk container of hazardous material, the shipper and carrier must follow specific preparation steps. The package itself must meet construction and performance standards, documentation must be complete and accurate, and the entire unit must be fit for transport. A citation here means an inspector found that your bulk package—or the way it was prepared or loaded—did not meet those baseline requirements.
What our enforcement data actually shows
Across our 13 million+ inspection records, 173.36 has been cited only 3 times all-time, with 2 citations in the last 12 months and 1 in the last 90 days. This makes it ranked #2551 of 3,036 FMCSR codes by citation volume—extremely rare.
But severity matters more than frequency here. Our data shows a 100.0% out-of-service rate for this code: all 3 citations resulted in vehicles being placed out of service. By contrast, the all-FMCSR average OOS rate is 31.4%. This code is cited only when inspectors find serious compliance gaps.
Who gets cited most
Our inspection records from the last 180 days show Texas with 1 citation and a 100.0% OOS rate. Because the citation volume is so low nationally, state-level comparison is limited. However, the fact that the single recent citation in Texas resulted in immediate out-of-service action underscores the enforcement profile: when 173.36 appears, it's treated as critical.
How severe is this compared to similar codes
Hazmat loading and placarding codes in the same category show much higher citation volumes but varied OOS outcomes. For example:
- 177.834A1 (general loading/unloading hazmat) has 3,954 citations with a 99.2% OOS rate—significantly more common and nearly as severe.
- 177.817(a) (placarding violation) has 2,274 citations with a 75.1% OOS rate—more frequent but lower enforcement severity.
- 172.502(a)(1) (placarding general requirements) has 1,820 citations with only an 18.5% OOS rate—far more common but much lower out-of-service threshold.
173.36's rarity combined with its 100% OOS rate suggests inspectors cite it only in egregious cases, making it one of the most serious hazmat preparation violations on record.
How to avoid it
Because 173.36 covers bulk package preparation and integrity, prevention centers on pre-transport inspection and documentation:
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Verify bulk package construction and integrity before loading. Check the container's condition, including welds, seals, and structural components. Inspect for any damage, corrosion, or leaks. Our co-occurring data shows that inspection and maintenance of parts—tracked separately under related codes—often appear alongside bulk package citations, indicating that containers with maintenance issues are cited together.
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Confirm all required placards, labels, and markings are present and legible. Bulk packages must display correct hazard class placards and proper identification numbers. Do not assume the shipper applied these correctly; verify them yourself before you leave the dock.
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Review the shipping papers and hazmat certification for completeness. The documentation must match the contents and the package classification. Missing or incorrect paperwork is a common pathway to 173.36 citations.
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Conduct a walk-around of the loaded vehicle, paying special attention to bulk containers. Look for signs of shifting, leaking, or loose securing equipment. The vehicle makes that have been cited (HEIL, INTL, KW, STLG) include specialized tanker and bulk carriers, so familiarity with your specific vehicle type's securing points is essential.
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Never assume the shipper got it right. As the driver, you are the final checkpoint. If anything about the package—its condition, labeling, or documentation—looks incomplete or incorrect, refuse to haul it and report the issue to your fleet's safety manager. A citation here can place your truck out of service immediately and derail your schedule; prevention is far simpler than aftermath.