What 173.36D2-HMGP means in plain language
FSMCR 173.36D2-HMGP falls under the federal hazardous materials transportation regulations. This code addresses specific packaging, labeling, or documentation requirements for hazardous materials shipments. When an inspector cites you for this violation, they've identified a deficiency in how hazardous material was prepared, marked, or handled before or during transport.
The regulation requires that hazardous materials meet precise standards for containment and identification. This protects you, other road users, and emergency responders by ensuring that if something goes wrong, everyone knows what they're dealing with. A citation under this code means an inspector found that your shipment or vehicle didn't meet one of those standards at the moment of inspection.
Unlike some hazmat violations that result in immediate out-of-service orders, this particular code does not automatically remove you from service. That distinction matters—it means the violation was documented but not deemed an immediate safety emergency by the inspector.
What our enforcement data actually shows
Across our 13 million+ roadside inspection records, 173.36D2-HMGP appears only once in all-time enforcement data. In the last 12 months, we recorded zero citations for this code, and zero in the last 90 days. This makes it one of the rarest hazmat citations in the national database.
When that single citation was issued, the vehicle was not placed out of service, resulting in a 0.0% OOS rate for this code. By comparison, the all-FMCSR average out-of-service rate stands at 31.4%, which means this violation, when it does occur, is typically handled as a correctable deficiency rather than an immediate removal from service.
Ranking nationally, 173.36D2-HMGP sits at #2796 out of 3,036 FMCSR codes by citation volume. The rarity of this citation suggests either that carriers and drivers are already compliant with this requirement, or that inspectors encounter very few shipments involving the specific conditions this code covers.
Who gets cited most
Our inspection data shows that this code has been cited so infrequently that identifying clear geographic or carrier patterns is not possible from our database. The single citation on record involved Brown Leaf Landscape (USDOT 2095207). The vehicles cited included a Freightliner and a Heil Co. unit.
Because enforcement volume is extremely low, you should not interpret absence of citations in any particular state or carrier group as permission to ignore the requirement. Instead, treat this as a reminder that the hazmat industry is heavily regulated across all regions, and compliance is expected everywhere.
How severe is this compared to similar codes
Hazmat violations range dramatically in enforcement frequency and severity. Our data shows peer codes in the same hazardous materials category that are cited far more often:
177.834A-HMC (General loading/unloading hazmat) has 3,954 citations with a 99.2% out-of-service rate—meaning inspectors almost always remove vehicles when loading or unloading procedures are found deficient.
177.817(a) (Placarding violation) has 2,274 citations with a 75.1% OOS rate, indicating that missing or incorrect placards are treated as serious safety hazards.
172.602(c)(1) (Maintenance/accessibility of Emergency Response information) has 1,464 citations but a 0.0% out-of-service rate, matching the profile of 173.36D2-HMGP—documented but not immediately disqualifying.
The contrast is stark: some hazmat violations trigger near-automatic removal from service, while others, including yours, are correctable on the spot or through follow-up documentation.
How to avoid it
Since this citation is rare, the specific trigger is not obvious from volume alone. However, if you've been cited for 173.36D2-HMGP, here are concrete steps to ensure it doesn't happen again:
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Verify packaging integrity before loading. Open every hazmat shipment box or container and confirm it matches the shipping papers. Look for damage, leaks, or signs that contents have shifted.
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Cross-check labels and placards. Ensure that every hazmat package label matches the placard on your vehicle, and that both match the hazmat classification on your shipping documentation. Mismatches are common citation triggers.
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Review your shipping papers in detail. Before departure, sit down with the bill of lading or manifest and confirm that the hazard class, UN number, proper shipping name, and quantity all align with labels and placards.
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Inspect your vehicle's placards and markings. Walk around your truck before and after each stop. Ensure placards are clean, visible, and securely fastened. Weathering and road grime degrade visibility fast.
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Know what you're carrying. Ask the shipper for a Safety Data Sheet (SDS) or hazmat information sheet if you're unfamiliar with the material. Understanding its properties helps you spot if something looks wrong.
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Document everything. Keep photos of loaded shipments, sealed containers, and placards. If an inspector later questions compliance, you have evidence of your care.
Hazmat compliance is not optional and violations—even rare ones—can result in fines, citations that affect your safety rating, and lost customer trust. The fact that 173.36D2-HMGP is rarely cited suggests the requirement is straightforward and most carriers meet it. Use this citation as a signal to audit your hazmat process end-to-end.