What 178.338-11(c) means in plain language
FMCSR code 178.338-11(c) applies to hazardous materials transport equipment. The regulation requires that thermal and mechanical remote closure devices on hazmat containers meet specific operational and structural standards. A "remote closure device" is a mechanism that allows a driver or handler to seal or open a hazmat tank or container from a distance, without direct manual contact.
When an inspector cites you for this code, they have determined that either the device is missing entirely from your vehicle, or it is present but not functioning properly. This could mean the remote control is broken, the mechanical linkage is damaged, or the thermal (heat-activated) component isn't responding as designed. The violation indicates a defect that could compromise the integrity of the hazmat package during transport.
This is a defect-based citation. It doesn't necessarily mean you attempted to transport hazmat improperly—only that the equipment itself failed inspection.
What our enforcement data actually shows
Across our 13 million inspection records, code 178.338-11(c) is rare. We have recorded 3 citations all-time for this violation, with zero citations in the last 12 months and zero in the last 90 days. This code ranks 2551st out of 3,036 FMCSR codes by citation volume.
None of the 3 all-time citations resulted in an out-of-service (OOS) order. The OOS rate for this code is 0.0%. For context, the all-FMCSR average OOS rate is 31.4%, meaning inspectors typically place vehicles with violations out of service roughly one-third of the time. The fact that no 178.338-11(c) citation has ever resulted in OOS placement suggests inspectors view this defect as repairable on-site or do not perceive immediate safety risk that warrants roadside removal from service.
Who gets cited most
Our inspection records show fleets such as American Refining Group Inc (USDOT 215284) with 1 citation, Victor Welding Supply Co (USDOT 974571) with 1 citation, and Teton Petroleum Transport LLC (USDOT 2353559) with 1 citation. The extremely low citation volume means there is no meaningful state or carrier pattern to report. Each of the three citations in our database involved a different carrier and different vehicle makes (Freightliner, Mack, and trailer).
How severe is this compared to similar codes
This code sits in the Hazardous Materials category. Other codes in the same category show vastly different enforcement profiles. General loading and unloading hazmat violations (codes 177.834A-HMC and 177.834(a)) account for 3,954 and 3,839 citations respectively, with OOS rates of 99.2% and 97.9%—meaning inspectors almost always remove vehicles for these violations. Placard violations (177.817(a)) have generated 2,274 citations with a 75.1% OOS rate.
By contrast, code 178.338-11(c) has only 3 citations and a 0.0% OOS rate. This reflects both its rarity and the fact that remote closure device defects, while cited, are not treated with the same enforcement severity as loading, unloading, or placarding failures. The defect is fixable and does not inherently render the hazmat transport unsafe in the same way a missing placard or improper loading does.
How to avoid it
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Inspect remote closure mechanisms during your pre-trip walk-around. Check that any thermal or mechanical remote control on your hazmat tanks or containers operates smoothly. Activate it from a distance to confirm response. If it sticks, fails to open or close, or shows visible damage, report it to your dispatcher before loading.
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Know your equipment. If you are assigned a hazmat tanker or container with a remote closure system, understand how it works and what full closure looks like. Ask your safety team or training supervisor to walk you through operation during onboarding.
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Schedule maintenance on closure systems proactively. Do not defer repairs to remote controls, hydraulic or pneumatic linkages, or thermal switches. A small malfunction caught during maintenance is far easier and cheaper than a roadside citation.
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Document pre-trip findings. If you inspect a remote closure device and it works, note that in your pre-trip report. If you find a defect, photograph it and report it immediately in writing. This creates a record that you caught the problem before the load moved.
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Request equipment swap if needed. If your assigned vehicle has a faulty remote closure device and repairs are not immediately available, ask dispatch to assign you different equipment. A short delay beats a citation and potential liability if the device fails during transport.