What 396.5A means in plain language
Code 396.5A citations are issued when an inspector finds an oil or grease leak coming from your engine, transmission, or other major vehicle components. This isn't a minor cosmetic issue—leaking oil or grease can damage your truck's mechanical systems, contaminate roadways, and indicate deeper maintenance problems that could lead to component failure while you're driving.
The regulation requires that your commercial motor vehicle be maintained so that it does not have active leaks of this type. A leak doesn't have to be massive to trigger a citation. Inspectors are trained to spot even small seeps and drips that suggest inadequate maintenance or a developing fault.
What our enforcement data actually shows
Across our 13 million+ inspection records, 396.5A is a relatively uncommon citation. All-time, we've recorded 29 citations for this code, with 13 citations in the last 12 months and 2 in the last 90 days. That makes 396.5A ranked #1816 of 3,036 FMCSR codes by citation volume—meaning most drivers and fleets will never encounter this one.
When cited, this code does not result in an out-of-service order as often as many other violations. Our data shows a 20.7% out-of-service rate for 396.5A all-time (6 OOS placements out of 29 total citations). This is notably lower than the all-FMCSR average OOS rate of 31.4%, which suggests that inspectors are more likely to issue a citation-only notice and allow you to continue operating while you arrange repairs.
That said, if you are placed out of service, you cannot legally operate your truck until the leak is fixed and reinspected. The citation itself will appear on your record and may affect your carrier's safety profile in the CSA system.
Who gets cited most
Over the last 180 days, our inspection records show citations for 396.5A concentrated in a small number of states. Iowa leads with 5 citations and a 20.0% OOS rate. Illinois and New Mexico each had 1 citation with no out-of-service placements. Texas also had 1 citation, but that case resulted in an out-of-service order (100% OOS rate for that single case).
The variation in OOS rates across these states reflects differences in inspector enforcement practices and the severity of leaks encountered. Iowa's 20.0% rate aligns roughly with the national 20.7% rate for this code.
Looking at carriers in our database with the most citations for 396.5A, our data shows fleets such as Wilmore and Anderson LLC with 3 citations all-time, and Highway to Heaven Trucking Incorporated with 2 citations. These numbers are small in absolute terms and do not indicate a systemic problem; they simply reflect which carriers operated the vehicles that were inspected and cited during the periods in our database.
How severe is this compared to similar codes
To put 396.5A in context, consider these related vehicle maintenance violations:
393.11 (Lighting devices/reflectors) has been cited 179,734 times across our database with only a 1.8% OOS rate. That's far more common and usually results in a warning or citation without vehicle removal.
396.3(a)(1) (Inspection/repair/maintenance - general) is a broader catch-all that encompasses any maintenance defect and has been cited 236,919 times with a 45.3% OOS rate. That code is enforced much more aggressively and frequently results in immediate out-of-service orders.
396.17C-PI (No proof of periodic inspection) appears 212,081 times in our records with a 0.0% OOS rate—it's a paperwork violation, not a mechanical one.
By this comparison, 396.5A sits in the middle: less common than broad maintenance violations like 396.3, but when cited, it has a moderate likelihood of resulting in an out-of-service order. The 20.7% OOS rate suggests that not every oil or grease leak triggers an immediate roadside vehicle removal.
How to avoid it
Prevention is straightforward and far less costly than roadside repairs or downtime:
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Perform a thorough pre-trip inspection of your engine compartment. Look underneath the engine, around the transmission pan, and along the oil cooler lines. Wipe away existing dust or dried oil so you can spot fresh leaks. If you see wet spots or active drips, do not depart—contact your carrier's maintenance team immediately.
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Check your engine oil level and condition at every stop. A low oil level is often the first sign of a leak. Top it off if needed, and use a clean rag to inspect the dipstick for signs of leakage.
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Pay attention to your dashboard warning lights. Many modern trucks have low-oil-pressure or oil-level warning systems. If these illuminate, pull over safely and investigate before continuing.
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Report leaks to your dispatcher or maintenance team without delay. Do not ignore small seeps hoping they'll go away. Leaks tend to worsen, and a minor repair now prevents a citation and vehicle removal later.
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Maintain a regular inspection and maintenance schedule with your carrier or independent shop. Have your technician check transmission fluid levels, engine gaskets, and cooling system integrity at each service interval.
Our inspection data shows that 396.5A citations are rare, but they are preventable. The difference between a citation and a clean inspection often comes down to basic pre-trip diligence and prompt communication with your maintenance team.