What 178.338-18A means in plain language
FMCSR 178.338-18A requires that MC338 cargo tanks display proper name plates and specification plates. These plates are permanent, metal identification markers that must be affixed to the outside of the tank. The name plate identifies the tank's manufacturer and shows critical technical data. The specification plate displays pressure ratings, material type, and other design specifications that inspectors rely on to verify the tank meets federal standards.
When either plate is missing, damaged beyond legibility, or has been removed, you're in violation of this code. This isn't about temporary labels or placards—it's about the permanent metal credentials that prove your tank was built to code and is safe to haul hazmat.
What our enforcement data actually shows
Across our 13 million+ inspection records, this code ranks #2796 out of 3,036 FMCSR codes by citation volume, making it one of the least-cited hazardous materials violations in our database. Our inspection records show only 1 citation all-time, with 0 citations in the last 12 months and 0 in the last 90 days.
The out-of-service rate for 178.338-18A stands at 0.0%—meaning the single vehicle cited was not placed out of service. This is significantly lower than the all-FMCSR average OOS rate of 31.4%, and substantially lower than most peer hazmat codes, which often trigger roadside removal due to the safety risks they represent.
Who gets cited most
Our data shows that enforcement of this specific violation has been extremely limited in our inspection database. The citation on record involved ISMAEL CASTILLO HERNANDEZ (USDOT 4084903) with 1 citation. Vehicle data indicates citations have been documented on RAM and RCON units, though the sample size is too small to suggest a pattern across fleets or manufacturers.
How severe is this compared to similar codes
Placarding and hazmat tank identification violations fall into a spectrum of enforcement severity. Compare 178.338-18A to peer codes in the hazardous materials category:
- 177.834A-HMC (General loading/unloading hazmat) has generated 3,954 citations with a 99.2% out-of-service rate—reflecting the critical safety nature of improper hazmat handling.
- 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 roadside violations.
- 172.516(c)(6) (Placard damaged, deteriorated, or obscured) has 1,796 citations but only a 1.6% OOS rate, showing that visibility and condition of placards are treated more leniently than presence itself.
The extreme rarity of 178.338-18A citations in our database suggests that most carriers keep specification and name plates intact, or that inspectors prioritize other hazmat violations when conducting roadside checks.
How to avoid it
Before accepting a hazmat load:
- Walk around the entire tank and visually inspect both the name plate and specification plate. They should be metal, permanently mounted, and clearly readable from a distance of 3 feet.
- If either plate is missing, dented beyond legibility, or showing signs of corrosion that obscures the text, refuse the load until the carrier replaces the plate.
- Take a photo of both plates for your pre-trip documentation. This creates a record that you verified compliance before departure.
During your trip:
- Avoid parking under low clearances, tree branches, or in areas where the tank might be struck or scraped. Physical damage to plates can render them illegible.
- If your tank is involved in any collision or near-miss, inspect the plates immediately and report damage to your dispatcher.
- Do not attempt to repair, repaint, or alter the name plate or specification plate yourself. These are factory-installed credentials.
Before roadside inspection:
- Position your vehicle to allow the inspector clear access to both sides of the tank where plates are mounted.
- Have your shipping papers and tank registration readily available to cross-reference the information on the plates.
Keeping your MC338 tank's credentials intact is a straightforward compliance task that prevents a violation entirely.