What 178.338-10(c) means in plain language
178.338-10(c) governs the packaging and labeling requirements for hazardous materials in transport. This regulation ensures that hazmat shipments are properly contained and clearly identified so that emergency responders, dock workers, and other handlers understand what they're dealing with at every stage of the journey.
When you're cited for this code, it typically means an inspector found that your hazmat load did not meet packaging standards, labeling was missing or illegible, or the materials were not properly secured in their containers. This could be a loose cap on a chemical drum, faded labels that can't be read, or packaging that shows signs of damage or deterioration.
The regulation exists because hazmat incidents—spills, leaks, or exposure—create immediate dangers for you, your cargo, other drivers, and the communities your truck passes through. FMCSA takes hazmat compliance seriously, and so should you.
What our enforcement data actually shows
Across our 13 million+ inspection records, 178.338-10(c) is cited relatively rarely. We have recorded 10 all-time citations for this code, with 0 citations in the last 12 months and 0 in the last 90 days. This ranks 178.338-10(c) at #2191 out of 3,036 FMCSR codes by enforcement volume.
Of the 10 all-time citations on record, none resulted in an out-of-service order—giving this code a 0.0% OOS rate. For context, the all-FMCSR average OOS rate is 31.4%, so this code is placed out of service far less often than most violations. This does not mean the citation is minor; it reflects that inspectors typically issue this citation and allow the driver to proceed after correcting the defect, rather than removing the vehicle from service immediately.
The low volume and zero recent citations suggest that most carriers have strong compliance with this particular aspect of hazmat transport, or that violations are being caught and corrected before they reach the roadside.
Who gets cited most
Our data shows 10 carriers with one citation each for 178.338-10(c), including Woodward Hull Inc, PGW Autoglass LLC, and 2051782 Ontario Ltd. No single carrier dominates the citation count, and no state data is available to identify concentration patterns. The small enforcement volume makes trend analysis across states or fleets impractical at this time.
The vehicle types involved in these 10 citations included a mix of makes—HYTR, KW, PTRB, and VANR each appearing once—suggesting no particular vehicle platform is more prone to this violation.
How severe is this compared to similar codes
178.338-10(c) sits at the lower end of severity when compared to other hazmat-related violations in our database. For example:
- 177.834A-HMC (General loading/unloading hazmat) has 3,954 citations and a 99.2% OOS rate—nearly 400 times more frequent and almost always results in vehicle removal.
- 177.817(a) (Placarding violation) has 2,274 citations with a 75.1% OOS rate—also far more common and more likely to ground the truck.
- 172.502(a)(1) (Placarding general requirements) has 1,820 citations with an 18.5% OOS rate—similar volume to some peer codes but higher OOS frequency.
Your 178.338-10(c) citation, by contrast, reflects a lower-severity packaging or labeling defect that inspectors believe can be corrected without immediately removing the vehicle from the road.
How to avoid it
Preventing a 178.338-10(c) citation means treating your hazmat packaging and labels as mission-critical during pre-trip and ongoing transport:
- Inspect container seals and caps before loading. Check that all hazmat drums, jugs, bottles, or other containers are tightly sealed and show no signs of leakage or damage. A loose cap or cracked container is a guaranteed citation.
- Verify all labels are present, legible, and correctly positioned. Before departure, walk around your load and confirm that every hazmat package displays the required label or placard. Labels must be readable from at least three feet away; if printing is faded or smudged, request a relabeled shipment.
- Check packaging for physical damage. Look for dents, cracks, rust, or corrosion on drums or containers. If a container has been in a previous accident or shows deterioration, refuse to accept it and notify your dispatcher.
- Secure containers against movement. Ensure all hazmat packages are properly blocked, braced, or restrained so they cannot shift, topple, or rub against each other during transit. Movement can damage containers and labels.
- Document your pre-trip inspection. Photograph or note the condition of hazmat packaging and labels before you leave the shipper. This creates a record that defects, if found at roadside, occurred after your departure—not during loading.
- Know your manifest. Verify that the shipping documents match the physical cargo and that all hazmat descriptions, proper shipping names, and hazard class labels are correct on paper before you roll.
These steps take 10–15 minutes per load but prevent citations, delays, and potential safety incidents that could end your career.