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OS Error Code 32 in a Docker container when using BULK INSERT can occur due to a few reasons:

1. Insufficient Permissions: The SQL Server user account running the container might not have sufficient permissions to access the file path where the BULK INSERT command is pointing to.

2. Wrong File Path: The file path specified in the BULK INSERT command might be incorrect or does not exist within the container. This can happen when the file is not mounted correctly or located outside the container.

3. File in Use: If the file is currently in use by another process or program, the BULK INSERT command may fail with the OS Error Code 32.

To resolve this issue, you can try the following steps:

1. Ensure that the SQL Server user account running the container has sufficient permissions to access the file path.

2. Verify that the file path specified in the BULK INSERT command is correct and exists within the container.

3. Check if the file is currently in use by another process or program and close it before running the BULK INSERT command.

4. Ensure that the file is mounted correctly into the container.

5. Check if the file is not corrupted or the format is not supported within the container.