FMCSR 177.848D: Prohibited Hazmat Loading — Q&A

Yes—80% of the time. Across our inspection records, drivers cited for prohibited hazmat loading and storage combinations were placed out of service in 4 out of 5 cases. That's significantly higher than the all-FMCSR average OOS rate of 31.4%. Once an OOS citation is issued, your vehicle cannot legally operate until the violation is corrected and re-inspected.

First: stop moving the load. Second: identify the problematic material combination and segregate or unload accordingly. Third: check your placarding (172.502A1 and 172.504A violations often co-occur with 177.848D per our data). Fourth: verify packaging compliance (173.24B1 and 173.24C show up together). Finally: request a re-inspection once corrections are complete. Do not attempt to move the vehicle while OOS.

It's on the severe end. While 177.848D ranks #2406 of 3,036 FMCSR codes by total citation volume (only 5 all-time), its 80% OOS rate far exceeds peer violations. For comparison, general loading/unloading hazmat violations (177.834A-HMC) carry a 99.2% OOS rate, and placard violations (177.817a) have 75.1%. 177.848D reflects a fundamental safety failure in cargo segregation.

Citations are rare but consistent. Our inspection records show 4 citations in the last 12 months, with the most recent spike in May 2025 (2 citations). The 90-day volume is 1 citation, suggesting enforcement remains episodic rather than trending upward. When inspectors do cite this violation, the OOS rate stays high: all 4 recent citations resulted in 1 or more OOS placements.

Texas leads in the last 180 days with 2 citations, both resulting in out-of-service orders (100% OOS rate). Our dataset does not show sufficient citation volume in other states to rank them reliably. If you operate hazmat routes in Texas, ensure your load segregation procedures meet spec—the state has seen the most enforcement activity on this code.

Yes. FMCSA's DataQs (Dispute Resolution) process allows drivers and carriers to challenge roadside inspection findings within specific timeframes. For a loading/storage violation like 177.848D, contestability depends on whether the inspector's determination was factual and documented. If placarding or packaging codes co-occur (as they do in our data), contest all related citations together. Consult your carrier's safety team or a compliance specialist for your specific case.

Across our all-time records, Volvo and Freightliner are the most frequently cited makes (2 and 1 citations respectively). Single citations also appear for Gardener, International, Utility, and Wanco. This violation is not make-specific—it reflects driver and shipper error in load planning rather than equipment design. Any vehicle hauling hazmat is vulnerable if incompatible materials are loaded together.

Both. Under FMCSA's Compliance, Safety, Accountability (CSA) framework, hazmat violations populate both driver and carrier safety profiles. The citation stays on your record for 36 months and affects your carrier's hazmat BASIC score. If you were following company procedure and the violation stems from shipper misdeclaration or dispatch error, document that for your safety manager—but the citation itself affects both parties until it ages out.