FMCSR 180.352(b): Rigid IBC Retest Date Marking Q&A

No. Across our 13 million inspection records, none of the 7 all-time citations for 180.352(b) resulted in an out-of-service placement—a 0.0% OOS rate. This is significantly lower than the 31.4% average across all FMCSR codes and far below related hazmat violations like general loading/unloading hazmat (99.2% OOS) or placarding violations (75.1% OOS). That said, inspectors may still cite this as a documentary finding requiring correction, so address it promptly to avoid follow-up issues.

Much less serious. Our data shows 180.352(b) ranks #2312 out of 3,036 FMCSR codes by citation volume, with only 7 all-time citations. Compare that to peer hazmat codes in the same category: general loading/unloading violations have 3,954 and 3,839 citations respectively, and placarding violations exceed 1,700 citations each. The near-zero enforcement volume suggests inspectors rarely cite rigid IBC retest date marking, making this a lower-priority compliance area than core hazmat documentation or placarding.

Take these steps immediately:

1. Document the citation details — note the inspector's findings and the specific rigid IBC container involved.
2. Inspect all IBC containers in your operation or fleet for retest date markings and legibility.
3. Check certification records — verify retest dates match markings and that certifications are current.
4. Correct or replace any containers with missing, faded, or illegible retest date markings.
5. Implement a pre-trip inspection checklist that includes verifying IBC markings on hazmat loads.
6. Review the citation with your carrier or fleet manager to determine if this is an isolated finding or systemic gap.

No, it's rare. Our inspection data shows only 7 citations for 180.352(b) in the entire database, with zero in the last 12 months and zero in the last 90 days. The most-cited company, Bosque Disposal Systems LLC (USDOT 2086894), received 4 of those 7 citations. This extremely low enforcement volume indicates either very few carriers operate rigid IBCs requiring retest date marking, or the marking requirement is widely understood and met. Either way, if you're cited, you're among a small group of operators inspectors have actually checked on this specific violation.

Yes, you can contest any citation through the DataQs roadside dispute resolution system if you believe the finding was inaccurate or the inspector made an error. Since 180.352(b) concerns equipment marking and documentation, you can challenge it if:

• The marking was actually present and legible at the time of inspection.
• The container was not required to bear a retest date marking under the regulations.
• The citation was issued in error or confused with another container.

File your DataQs challenge through your carrier's safety department or directly via FMCSA's online portal. Include photos or documentation of the container and retest date marking if available.

Our enforcement records are too sparse to identify a clear geographic pattern—only 7 citations all-time limits state-level analysis. The citations we do have are scattered across different carriers and vehicle types (Ford, Freightliner, and other), suggesting this violation is flagged inconsistently across regions rather than concentrated in specific states. If you operate rigid IBCs, monitor your local inspection trends and work with your fleet safety team to ensure marking compliance nationwide rather than assuming risk is localized.

Citations for 180.352(b) are recorded in your carrier's and driver's FMCSA inspection history, and they may factor into CSA scores depending on how inspectors categorize the finding. However, the 0.0% out-of-service rate and minimal citation volume suggest this is treated as a lower-severity compliance matter, not a critical safety finding. To understand the specific impact on your CSA points and carrier profile, review the citation with your safety manager and check your motor carrier safety report at SafetyInsight.FMCSA.DOT.gov or your company's safety dashboard.

Enforcement is essentially inactive. Our inspection records show zero citations for 180.352(b) in the last 12 months and zero in the last 90 days, despite 13 million total roadside inspections in our database. This sharp drop from 7 all-time citations suggests enforcement attention on rigid IBC retest date marking has stopped or is extremely sporadic. That doesn't mean you can ignore it—compliance is still required—but it does indicate inspectors are not prioritizing this violation in current roadside operations.