What 180.605(k) means in plain language
When you transport hazardous materials, containers and packaging must carry certain markings so emergency responders and inspection officers can identify what's inside. One critical marking is the date when the container or packaging was last tested for safety.
180.605(k) requires that this test date be clearly marked and visible on the hazmat packaging or container. The date shows that the container has been inspected and certified safe to hold the material under pressure or for containment during transport. If the marking is missing, faded, illegible, or applied incorrectly, you're in violation—even if the container itself is sound.
This rule applies whether you're hauling compressed gases, liquids, or other regulated hazardous materials in DOT-approved packaging. The inspector at roadside is looking to confirm that every container in your load displays a readable test date.
What our enforcement data actually shows
Across our 13 million inspection records, 180.605(k) has generated 27 citations all-time. In the last 12 months, we've recorded zero citations for this code, and zero in the last 90 days. This makes 180.605(k) the least-cited hazmat test-date-marking violation in our database, ranking #1838 of 3,036 FMCSR codes by citation volume.
When a citation is issued, the likelihood of being placed out of service is very low. Our data shows a 3.7% out-of-service rate for this code—meaning 26 out of 27 citations resulted in a warning or written violation without vehicle removal from service. By comparison, the all-FMCSR average out-of-service rate is 31.4%, so this violation is dramatically less likely to sideline your truck than many others.
The rarity of citations suggests that test date markings are either widely compliant or infrequently inspected in detail at the roadside. Either way, if you've been cited, you're in a statistical minority.
Who gets cited most
Our inspection records do not break citations for 180.605(k) by state, so we cannot identify a geographic hotspot. However, the carriers cited for this violation appear in small numbers across the database. TRANSMAQUILA SA DE CV and GARY V BURROWS INC each received 2 citations; the remaining eight carriers cited received 1 citation each. This distribution indicates that test date marking violations are scattered rather than concentrated in any single fleet.
The vehicle makes involved in cited 180.605(k) violations were predominantly Kenworth and Freightliner units, along with other specialized hazmat tanker builders (OTHR, KW, FRHT codes). This pattern reflects that hazmat haulers use specific truck platforms designed for bulk transport—these are the vehicles most likely to carry the regulated materials that require test-date-marked containers.
How severe is this compared to similar codes
Test date marking sits within the broader hazardous materials compliance category. To put its severity in perspective, consider these related violations our data tracks:
Placarding and loading violations dominate the hazmat enforcement space. 177.834A (general loading/unloading hazmat) has 3,954 citations with a 99.2% out-of-service rate—nearly every citation results in vehicle removal. 177.817(a) (placarding violation) shows 2,274 citations at 75.1% OOS rate. These are serious, frequent stops.
Placard-specific damage or deterioration (177.817(e)) has 2,038 citations but only a 5.2% OOS rate—similar low-enforcement outcome to 180.605(k). And 172.516(c)(6) (placard damaged, deteriorated, or obscured) has 1,796 citations at just 1.6% OOS rate.
The pattern is clear: cosmetic or marking issues like test date visibility trigger citations rarely and result in out-of-service removals even more rarely, while actual loading and placarding defects drive the majority of hazmat enforcement and lead to immediate vehicle removal. Your citation is at the low-severity end of the hazmat enforcement spectrum.
How to avoid it
Test date marking violations are preventable with a straightforward pre-trip inspection discipline:
-
Walk every hazmat container before loading. Check that the test date is legible, present, and matches DOT format standards. Use a flashlight if needed—faded ink is a citation waiting to happen. Do this in daylight or under good lighting; an inspector will.
-
Know your DOT packaging. If you're hauling hazmat, you should know whether your containers are spec'd for 5-year or 10-year test intervals. Expired test dates are a compliance failure. Confirm with your shipper or fleet maintenance that all packaging is current before departure.
-
Document pre-trip marking checks on your vehicle inspection report. Write down that you verified test date markings. This creates a record and reinforces the habit. If cited, it demonstrates due diligence.
-
Train on container inspection at your fleet. If your company hauls hazmat regularly, include test date marking verification in your safety briefing. Share this data with your team: 27 citations across 13 million inspections means this rule is enforced lightly, but when it is, compliance is expected.
-
Report faded or unclear markings to your dispatcher or shipper immediately. Do not accept a load if markings are illegible. A few minutes of communication beats a roadside citation and the administrative burden that follows.
Your citation is statistically unusual and carries low enforcement risk, but it signals that an inspector examined your hazmat packaging closely. Use it as a reminder to document and verify before you roll.