FMCSR 393.100(b) Cargo Securement Aggregate Load: Driver FAQ

Yes — almost certainly. Across 16,155 all-time citations in our inspection records, 15,622 resulted in an out-of-service order, giving 393.100(b) a 96.7% OOS rate. That is not a typo. The all-FMCSR average OOS rate is 31.4%, meaning this violation puts trucks out of service at more than three times the average rate. If an inspector finds that your cargo securement devices don't collectively meet the required working load limit, you are not moving that load until the problem is corrected on the spot. Plan for a roadside fix or an unloaded vehicle.

393.100(b) carries a severity weight of 6 in the CSA scoring system. That base score is then multiplied based on how recently the violation occurred — inspections within the last 6 months receive the highest multiplier (3×), dropping to 2× between 6 and 12 months, and 1× beyond that. So a fresh citation effectively hits your BASIC score as a 18-point event before any time decay. Because this falls under the Vehicle Maintenance BASIC, it accumulates against both the carrier's Safety Measurement System profile and the driver's Pre-Employment Screening Program (PSP) record.

Stop and fix the securement before moving the load. Here's what to do immediately:

1. Do not move the vehicle under load until a qualified person verifies your securement devices collectively meet the required aggregate working load limit.
2. Document everything — photograph the load, the tie-downs, anchor points, and the inspection report.
3. Contact your fleet safety manager or dispatcher immediately so the carrier can log the event and begin a corrective action record.
4. Obtain replacement or additional securement devices that bring the aggregate rating into compliance.
5. Request a re-inspection or clearance from the officer before re-entering traffic.

With a 96.7% OOS rate on this code, there is no gray area — compliance must be confirmed before you roll.

Yes — it is among the most severe vehicle maintenance violations by OOS rate. Our inspection records show a 96.7% OOS rate for 393.100(b), compared to peer codes in the same category: 396.3(a)(1) at 45.3%, 393.9(a) at 15.4%, 393.11 at 1.8%, and 393.78 at just 0.3%. No peer code in the category comes close to 96.7%. It also ranks #160 out of 3,036 FMCSR codes by total citation volume, meaning inspectors cite it regularly enough that it is well inside the top 6% of all enforced regulations. Fleet managers should treat any securement load-rating deficiency as an automatic shutdown event.

Yes, you can submit a DataQs Request for Data Review (RDR), but the bar is high for an equipment-based finding. Because 393.100(b) is a physical equipment violation — the securement devices either met the aggregate working load limit or they didn't — a successful challenge typically requires documentation proving the devices were actually compliant at the time of inspection (e.g., manufacturer ratings, tie-down count records, or a weight ticket showing the load was within limits). Clerical errors in the inspection report (wrong vehicle, wrong regulation code) are easier to correct. DataQs challenges do not remove a valid inspection from your record; they can only correct factual errors. Given the 96.7% OOS rate on this code, inspectors citing it are generally very confident in their finding.

Our inspection database does not break out 393.100(b) citations by state in the current data snapshot, so we cannot rank specific states for this code without risking an inaccurate claim. What the data does show is that all 16,155 citations are spread across carriers in multiple industries — waste haulers, construction, expedited freight, and owner-operators all appear in the top cited carriers list. If your operation runs heavy flatbed, construction material, or waste loads, enforcement exposure exists regardless of which state you're in, since aggregate working load requirements apply under federal FMCSR standards nationwide.

Extremely urgent — treat it as a zero-tolerance issue. The 96.7% OOS rate means that in our records, nearly every single citation results in a shutdown. There is virtually no history of inspectors citing this violation and letting the truck roll. While the last 12 months and last 90 days show 0 new citations in our current data snapshot, the all-time total of 16,155 citations — with 15,622 resulting in OOS orders — establishes a clear pattern: inspectors who identify this deficiency act on it decisively. For fleet managers, this means pre-trip securement audits should include verifying that the combined working load ratings of all devices meet or exceed the load's securement requirements, not just that straps are present.

It follows both. Under FMCSA's CSA system, a 393.100(b) citation is recorded against the carrier's Safety Measurement System (SMS) profile under the Vehicle Maintenance BASIC, affecting their safety percentile and potentially triggering intervention. It also appears on the driver's PSP (Pre-Employment Screening Program) record, where it stays visible to prospective employers for 3 years from the inspection date. Because this is an equipment-condition violation rather than a purely procedural one, both the carrier (responsible for vehicle maintenance) and the driver (responsible for pre-trip inspection and load securement) share accountability in how the industry and enforcement community view the record.