FMCSR 180.352B: Rigid IBC Retest Date Marking Q&A

No. Across our 13 million inspection records, citations for 180.352B have resulted in a 0.0% out-of-service rate. All 2 citations on record were issued without placing the vehicle out of service. This code is not OOS-eligible under FMCSA rules, meaning even if cited, your truck remains legal to operate. Compare this to the 31.4% average OOS rate across all FMCSR codes—180.352B is significantly less severe in enforcement impact.

First, document the inspection details and citation number. Second, check your rigid intermediate bulk container (IBC) retest date markings—verify they're clearly visible and current. If you were cited alongside other hazmat violations (our records show 180.352B co-occurs with closure/leakage checks), address those too. Third, contact your carrier's compliance manager and request a review of your hazmat documentation procedures. Fourth, preserve all IBC maintenance and testing records to support any challenge. Unlike equipment failures, this is primarily a documentation/marking issue, making it contestable if the inspector's finding is factually inaccurate.

180.352B is among the least cited hazmat codes in our database—ranked #2,651 of 3,036 FMCSR codes with only 2 all-time citations. Peer hazmat violations in the same category show vastly higher enforcement: general loading/unloading violations (177.834A-HMC) have 3,954 citations with a 99.2% OOS rate, and placard violations (177.817(a)) have 2,274 citations with a 75.1% OOS rate. At 0.0% OOS rate, 180.352B indicates this marking issue is treated as a minor documentation discrepancy, not a critical safety failure.

No significant trend. Our inspection data shows only 2 citations total in the last 12 months (1 in October 2025, 1 in February 2026), and 1 citation in the last 90 days. This is extremely low enforcement volume. The rarity of citations suggests either very few carriers are failing this requirement, or inspectors prioritize more serious hazmat violations. If you operate hazmat, this should not be a compliance priority relative to placarding and closure integrity violations.

In the last 180 days, our records show 1 citation in Texas. This represents the only state-level data available for this code. With only 2 all-time citations in our 13 million inspection database, enforcement is so sparse that geographic patterns are not meaningful. This does not indicate Texas is a hotspot for this violation—it simply reflects the rarity of the citation overall.

Yes, if the citation is factually inaccurate. DataQs (FMCSA's Roadside Data Quality Challenge System) allows drivers and carriers to contest inspection findings within 90 days. Since 180.352B is a marking and documentation issue, not an inherent vehicle defect, you have grounds to challenge if: the IBC retest date marking was actually present and legible, you can produce maintenance records proving current compliance, or the inspector's observation was incorrect. Submit supporting photos or documentation. Consult your carrier's compliance team or a safety counsel before filing.

Our all-time records show 2 carriers cited: EPBB INVESTMENT HOLDINGS LP (USDOT 1844515) with 1 citation, and K EXPRESS INC (USDOT 2439624) with 1 citation. This is not a pattern—each carrier has a single incident. The extreme rarity of citations means 180.352B is not a systemic issue for any carrier class.

The specific CSA point weight for 180.352B is not disclosed in our inspection database. Severity weights are set by FMCSA and applied within the CSA Hazardous Materials BASIC. For exact point values, consult the FMCSA's CSA severity matrix or contact your carrier's safety director. What we can confirm: with a 0.0% OOS rate and only 2 citations all-time, 180.352B is treated as a minor violation in enforcement practice, suggesting a lower severity classification than placarding or loading violations.