FMCSR 180.519 Citations: OOS Rate, Severity & What Drivers Need to Know

No. Across our 13 million inspection records, 180.519 citations have resulted in an 0.0% out-of-service rate—all 4 all-time citations were issued without placing the vehicle out of service. This is significantly lower than the 31.4% national average OOS rate across all FMCSR codes. While this violation relates to hazardous materials tank car documentation, the lack of OOS enforcement suggests inspectors are treating it as a documentation or marking issue rather than an immediate safety removal trigger.

180.519 is among the least-cited hazmat violations in our database. It ranks #2,480 out of 3,036 FMCSR codes by enforcement volume with only 4 all-time citations. By contrast, peer hazmat codes in the same category show vastly different enforcement patterns: placarding violations (177.817) average 75.1% OOS rates, while general loading/unloading violations (177.834A) hit 99.2% OOS rates. The near-zero citation frequency and zero OOS rate for 180.519 indicate it is a low-priority enforcement area relative to more common hazmat documentation failures.

First, verify the tank car's DOT 106 or 110 retest date markings are current and legible. Second, check your manifest and shipping papers match the tank condition. Third, document the citation details (inspector name, vehicle unit number, date) and file them with your carrier's compliance team. Fourth, if you operate for a carrier, notify your safety manager immediately—hazmat violations often trigger carrier audits. Finally, if you believe the marking was present but the inspector missed it, gather photographic evidence for a DataQs contestation, though documentation-based findings are typically harder to overturn than equipment defects.

No. Enforcement of 180.519 is extremely rare and shows no recent activity. Our records indicate 0 citations in the last 12 months and 0 in the last 90 days, despite 4 all-time citations in the database. This suggests the violation is either not a priority for roadside inspectors or occurs so infrequently that it seldom appears in active enforcement. If you are cited, it may indicate a particularly egregious marking deficiency or an inspector focused on detailed tank car documentation compliance.

This is a vehicle/equipment violation tied to the tank car's physical markings and condition documentation. Under FMCSA's CSA program, hazmat violations typically appear in both the driver's Hazardous Materials BASIC and the carrier's HM&E (Hazardous Materials and Hazardous Waste) safety profile. If you are cited while operating under a carrier, the violation will be assigned to the carrier as the primary responsible party, though your driving record may reflect it depending on whether you were driving at the time of inspection. Request clarification from your carrier on whose CSA account the citation was logged.

Our inspection data shows 180.519 citations are extremely scattered across carriers. The four all-time citations involved: Cherokee Freight Lines Stockton LLC (1 citation), Nuckles Oil Company Inc (1 citation), Premier Fuel Distributors Inc (1 citation), and Argus Trans Inc (1 citation). No single carrier shows a pattern, suggesting this violation is not concentrated among specific operators. If your carrier is not listed here, it is statistically unlikely to have a compliance issue with tank retest markings.

Yes, you can file a DataQs (SafetyNet Datapoint Query System) contestation through FMCSA's RDR (Roadside Data Repository). Since 180.519 is a documentation and marking violation, your case strength depends on whether you have photographic evidence of current, legible retest date markings at the time of inspection. If the marking was present but the inspector missed or misread it, evidence is compelling. Submit photos, maintenance records, and a detailed statement of the facts within 90 days of the citation. Documentation-based findings succeed more often than equipment defects when evidence is clear and timely.

Our records show two vehicle makes in the 180.519 citation history: Heil (1 citation) and Volvo (1 citation). Both are manufacturers commonly used for hazmat tanker construction. The extremely small sample (2 vehicles across 4 citations) means there is no discernible pattern by manufacturer. Tank cars from any OEM with improper or missing DOT 106/110 retest markings are equally vulnerable during inspection. Focus on marking compliance rather than vehicle type.