Unsecured packages remained the top violation of hazardous materials (hazmat) regulations uncovered by U.S. Department of Transportation (DOT) roadside inspections. What other violations made the top 10 list in fiscal year (FY) 2017? Let’s take a look and help you avoid DOT’s hazmat hit list.
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Don’t get caught short by a DOT roadside inspection. In FY 2017, DOT’s Federal Motor Carrier Safety Administration (FMCSA) performed 194,688 roadside inspections of trucks, targeting compliance with hazmat transportation regulations. During these inspections in FY 2017, DOT inspectors found 41,122 violations.
The top violation DOT inspectors found in FY 2017, as in FY 2016, is that packages are not secured in the vehicle. At 4,183 violations, this mistake accounts for over 10% of the total violations. Following at a distant second, inspectors have found 2,875 instances where there was no copy of the DOT hazmat registration number in the vehicle.
Placarding Blues
Placarding issues are always prominent in the top 10 hazmat violations list. Four of the top 10 violations in FY 2017 had to do with placarding requirements. In some cases, the placards were not provided to the carrier, or the vehicle was not properly placarded, or the placards were damaged or obscured, or there were no required placards or markings at all.
The DOT provides tons of information concern placarding, but it is often confusing. For instance, 49 CFR 172.506 requires that anyone offering hazmat for transportation in commerce provide the motor carrier with the required placards either before or at the same time the material is turned over to the carrier. But what exactly does “provide” mean when it comes to placards?
Well, DOT guidance here is a little hedgy. Since the hazmat regulations do not define “provide,” DOT officials fall back on dictionary definitions that it means “to make something available” and “to give something wanted or needed to someone or something.” Seems pretty clear, but confusing enough that guidance has been requested. So, DOT officials went on to offer examples that, in their opinion, would satisfy the requirement to “provide” placards to motor carriers. These include the offeror:
- Physically handing the applicable placards to the motor carrier;
- Physically applying the applicable placards to the container or vehicle; and
- Making the applicable placards available to the motor carrier in a manner such that the motor carrier can apply them to the appropriate container or vehicle.
We are left to wonder what making the placards available “in such a manner that the motor carrier can apply them” could mean in the Internet age.
Top 10 Hazmat Violations
Here’s a look at the top 10 hazmat transportation violations by trucks uncovered by DOT inspectors for FY 2017.
| Regulation | Violation Description | # of Inspections | # of Violations | % of Total Violations | |
| 1 | 49 CFR 177.834 | Package not secure in vehicle | 4,011 | 4,183 | 10.17% |
| 2 | 49 CFR 107.620 | No copy of U.S. DOT Hazardous Materials Registration number | 2,875 | 2,875 | 6.99% |
| 3 | 49 CFR 177.817 | Shipping paper accessibility | 2,236 | 2,252 | 5.48% |
| 4 | 49 CFR 172.504 | Vehicle not placarded as required | 2,044 | 2,112 | 5.14% |
| 5 | 49 CFR 172.516 | Placard damaged, deteriorated, or obscured | 1,946 | 2,036 | 4.95% |
| 6 | 49 CFR 177.817 | No shipping papers (carrier) | 1,920 | 1,938 | 4.71% |
| 7 | 49 CFR 172.506 | Failure to provide carrier required placards | 1,662 | 1,687 | 4.10% |
| 8 | 49 CFR 172.602 | Maintenance/accessibility of emergency response information | 1,280 | 1,281 | 3.12% |
| 9 | 49 CFR 177.823 | No placards/markings when required | 1,037 | 1,108 | 2.69% |
| 10 | 49 CFR 172.600 | Emergency response information not available | 1,073 | 1,078 | 2.62% |
Data Source: FMCSA Motor Carrier Management Information System
Where Is Your Emergency Response Information?
As mentioned, the top violation in both FY 2017 and FY 2016 was unsecured packages in vehicles. Interestingly, the violation that held the second spot in both years was the lack of a copy of the hazardous materials registration number.
As a matter of fact, 8 of the top 10 hazmat violations in FY 2016 also showed up as part of the top 10 in FY 2017. However, one violation that keeps lurking in or near the top 10 is maintenance and accessibility of emergency response information.
Check tomorrow’s Advisor for scenarios when DOT roadside inspectors think you are not maintaining or making accessible your emergency response information.