What 180.519 means in plain language
FMCSR 180.519 addresses the retest date markings required on DOT 106 and DOT 110 multi-unit tank car tanks. These are specialized containers used for transporting hazardous materials. The regulation requires that tanks have current, legible markings indicating when the tank was last tested and when the next test is due—critical documentation for proof that the tank is safe for use.
If you're hauling hazmat in one of these tank types, the inspection officer at the roadside is looking for those date markings to be clearly visible and current. Missing, illegible, or expired retest dates on the tank itself—not just paperwork—trigger this citation.
This is a documentation and condition requirement, not a structural or operational failure. It's about ensuring that every tank in a multi-unit configuration carries proof of its testing history right on the metal.
What our enforcement data actually shows
Across our 13 million inspection records, 180.519 is among the least-cited hazmat violations. All-time, we've recorded 4 citations nationally for this code—making it ranked #2480 of 3,036 FMCSR codes by citation volume.
None of those 4 citations resulted in an out-of-service order. The 0.0% OOS rate for 180.519 sits well below the all-FMCSR average of 31.4%, reflecting that inspectors treat this as a compliance documentation issue rather than an immediate safety threat to the vehicle.
Looking at recent enforcement trends, there have been 0 citations in the last 90 days and 0 in the last 12 months. This suggests that either carriers are maintaining excellent compliance, or inspectors rarely encounter violations of this specific marking requirement during roadside stops.
Who gets cited most
Our data shows fleets such as Cherokee Freight Lines Stockton LLC (1 citation) and Nuckles Oil Company Inc (1 citation) have been cited for 180.519. Because the total citation volume is so low, no single state dominates the enforcement pattern—citations are scattered across the national database.
The small number of citations means there's no meaningful state-by-state comparison to report. What this tells you is that 180.519 violations are rare events, affecting a tiny fraction of hazmat tank operations.
How severe is this compared to similar codes
180.519 sits in a category with other hazmat marking and documentation violations. For context:
177.834A-HMC (General loading/unloading hazmat) has accumulated 3,954 citations with a 99.2% out-of-service rate—far more frequent and much more likely to result in an immediate roadside shutdown.
177.817(a) (Placarding violation) shows 2,274 citations at a 75.1% OOS rate, also substantially higher enforcement frequency and severity.
172.602(c)(1) (Maintenance/accessibility of Emergency Response information) is closer in scope, with 1,464 citations and a 0.0% OOS rate, similar to 180.519 in that it's treated as a compliance documentation issue rather than a vehicle-removal event.
The comparison underscores that 180.519 is a low-enforcement, low-severity violation within the hazmat compliance landscape.
How to avoid it
Based on the conditions that trigger this citation, here are concrete steps to stay compliant:
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Before every trip, conduct a pre-trip walk-around of your tank car. Specifically look for the retest date markings on the side or end of the tank. They should be clearly visible, not obscured by dirt, rust, or damage.
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Verify the retest date has not expired. The marking tells you when the next hydrostatic or other required test is due. If that date has passed, the tank should not be in service and must be removed from the unit immediately.
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Check that markings are legible and in durable paint or stamped metal. Faded, peeling, or partially visible markings can trigger a citation even if the tank is technically within its test window.
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Coordinate with your carrier's tank maintenance program. Ensure that when tanks are returned for retest after expiration, the new date markings are applied before the tank re-enters your fleet rotation.
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Report any tank with missing or illegible markings to your fleet manager before rolling out. Do not attempt to repair or re-paint the markings yourself—that's a maintenance/compliance function for the carrier.
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Know your tank type. If you're assigned a DOT 106 or DOT 110 multi-unit tank car, familiarize yourself with where these markings are typically located and what legible markings look like on a new tank, so you can spot degradation early.
Because enforcement is rare, 180.519 citations usually mean the tank was already past its retest date or the markings had physically deteriorated. A brief visual check during pre-trip inspection will nearly eliminate your exposure to this violation.