FMCSR 173.36 Q&A: Large Bulk Packages Citation Guide

Yes, this citation almost certainly results in an out-of-service order. Across our 13 million inspection records, the 173.36 large bulk packages violation carries a 100.0% out-of-service rate—meaning every single citation we've tracked resulted in the vehicle being placed out of service. This is far higher than the 31.4% average OOS rate across all FMCSR codes, indicating inspectors treat this hazmat violation as an immediate safety risk.

173.36 is extremely serious in the hazmat category. While we see far fewer 173.36 citations (3 all-time) than related loading/unloading violations like 177.834A-HMC (3,954 citations at 99.2% OOS rate), the 100.0% OOS rate for 173.36 indicates zero tolerance. By comparison, placard violations like 172.502(a)(1) sit at only 18.5% OOS. Our database shows 173.36 ranks #2551 of 3,036 FMCSR codes overall—rare but consistently severe.

First: do not move the vehicle. You are out of service. Second: document the condition of the cargo and packaging as cited. Third: contact your dispatcher and company safety officer immediately—this is a federal hazmat violation. Fourth: inspect your large bulk package for damage, deterioration, or non-compliance with loading requirements. In our records, 173.36 co-occurs with inspection/repair code 396.3A1, suggesting underlying mechanical or equipment issues may be involved. Have those addressed before reloading.

In the last 180 days, our inspection data shows 173.36 was cited 1 time in Texas—the only state in our top-citation list for this code. The extremely low citation volume (1 in TX, 2 nationwide in the last 12 months, 1 in the last 90 days) suggests this violation is rare nationally and not concentrated in any particular region. Texas is the only state where we have documented enforcement data for this code.

Yes, you can submit a DataQs challenge through FMCSA's roadside data review process if you believe the citation is factually inaccurate or unjustly applied. The 173.36 violation involves objective assessment of large bulk package requirements—damaged packaging, improper securing, or deteriorated containers are typically observable facts. Document photos, loading records, and maintenance logs before submission. Success depends on whether the inspector's finding was documentation-based or equipment-based; physical damage findings are harder to overturn.

Across our 13 million+ inspection records, only three carriers have citations for 173.36: Midtex Oil LP (USDOT 922403), Rocky Mountain Crude Oil LLC (USDOT 2820483), and Southmark Aviation Inc (USDOT 3407009)—each with 1 citation. This is extremely rare data; the violation itself appears only 3 times in our entire database, suggesting it reflects very specific hazmat bulk loading practices or equipment types rather than a widespread compliance issue.

Urgent. The 100.0% out-of-service rate means you cannot legally operate until compliance is verified by a safety official. In the last 90 days, we saw 1 citation for this code. Historically, citations cluster around hazmat loading seasons—we documented citations in September 2025 and February 2026. Do not attempt to haul large bulk packages until the citation is resolved and your cargo handling procedures are re-certified by your carrier's safety director.

Both. In FMCSA's CSA system, hazmat violations record against the carrier's safety profile and your personal driving record. A 173.36 citation affects the carrier's Hazardous Materials BASIC category and your individual Driver Violation/Safety Defensiveness record. This impacts the carrier's SMS score and your hiring eligibility with future carriers—prospective employers see hazmat citations on your PSP record. Expect this to remain visible for 3 years on your CSA record.