FMCSR 177.835 Q&A: Cargo Tank Loading/Unloading

No. Across our inspection database, 177.835 has not resulted in any out-of-service placements — the OOS rate is 0.0%. This contrasts sharply with related cargo tank violations like 177.834A (99.2% OOS rate) and 177.834(a) (97.9% OOS rate), which are enforced far more frequently and almost always result in immediate vehicle removal from service. 177.835 citations are rare enough that they carry no documented out-of-service history in our 13 million+ inspection records.

177.835 carries a CSA severity weight of 7, which means each citation generates 7 points in your Safety Management Cycle. The actual impact depends on the 30-day look-back window: if you receive multiple citations within that period, the points stack. However, given that our inspection records show zero citations for this code in the last 12 months, the practical risk of accumulating points from this violation is extremely low.

Step 1: Request the inspection report and documentation from the DOT officer — ensure the specific loading or unloading deficiency is clearly stated. Step 2: Review your cargo tank's maintenance and operational logs for the date of citation. Step 3: If the finding relates to equipment condition or documentation, gather records proving compliance or remediation. Step 4: Consider filing a DataQS challenge if the citation is based on an officer observation without supporting evidence or if your records show proper procedure was followed. Step 5: If safety procedure is the issue, retrain and document the correction with your dispatcher or fleet manager.

177.835 is among the least-enforced hazmat loading violations. Our data shows nearly identical codes — 177.834A and 177.834(a) — account for 3,954 and 3,839 citations respectively, with out-of-service rates above 97%. Meanwhile, 177.835 has zero citations on record. This suggests either that the specific conduct it targets is rare, or that inspectors cite the broader codes instead. Relative to placarding violations (177.817(a): 2,274 citations) or damaged hazmat package movement (177.823(a): 1,829 citations), a 177.835 citation is unusual and warrants close document review.

Yes. The DataQS Road Data Request system allows you to challenge safety data records, including inspection findings. For 177.835, contestability depends on the type of violation: if the officer cited you for a documented procedure violation (e.g., failure to follow a specific loading step), you can challenge by providing photos, written procedures, or witness statements showing compliance. If the citation is equipment-based (tank condition, valve operation), submit maintenance records or repair invoices as evidence of correction. File your challenge within 90 days of the inspection; include the inspection report number and detailed rebuttal with supporting docs.

We cannot identify the top states for 177.835 enforcement — our inspection records show zero citations for this code in the last 12 months and zero all-time. This absence across all states in our 13 million+ record database suggests this particular violation is either extremely rare in practice or inspectors typically cite closely related codes like 177.834A or 177.834(a) instead. If you received a 177.835 citation, it is unusual enough to warrant detailed review of the inspection documentation.

Low immediate urgency from an OOS perspective. No 177.835 citations in our database have resulted in out-of-service placement, and the code shows zero enforcement activity in the last 90 days and last 12 months. However, if your citation involves a genuine safety deficiency in cargo tank loading or unloading — for example, failure to properly secure or position the tank — you should correct it before your next load. The CSA severity weight of 7 means the points will stay on your record for 34 months, so documenting the fix prevents future escalation.

Hazardous Materials violations under the BASIC 6 category are recorded against both the driver and the carrier in the FMCSA Compliance, Safety, Accountability (CSA) system. Your individual driver profile receives the 7-point severity weight, and your carrier's hazmat safety rating also reflects the violation. This dual attribution means that even a single citation can affect your hire-ability and your company's insurance rates and safety scores. Work with your fleet safety manager to document the corrective action and request data review if needed.