What 393.100(c) means in plain language
FMCSR 393.100(c) targets a straightforward but serious problem: cargo that moves when it shouldn't. The regulation requires that any load carried on or in a commercial motor vehicle be secured in a way that prevents it from shifting during transit — whether that means shifting side to side, front to back, or in any direction that could affect vehicle stability or create a hazard.
The core idea is that a properly loaded truck should arrive at its destination with its cargo in essentially the same position it was when it left. If a roadside inspector opens your trailer or looks at your flatbed and finds evidence that freight has moved — or that the securement in place is clearly insufficient to prevent movement — you're looking at a 393.100(c) citation.
This isn't limited to flatbed operations or oversized loads. Any commercial vehicle carrying cargo, from an LTL freight trailer to a pickup-style service truck, falls under this requirement. The obligation to secure cargo rests with the driver at departure and at every stop where the load could have shifted.
What our enforcement data actually shows
The numbers here tell a story that should get your attention. Across our database of 13 million+ inspections, 393.100(c) has generated 2,897 all-time citations, ranking it #447 out of 3,036 FMCSR codes by citation volume — meaning it sits in the top 15% of all tracked violations for how often it's written up.
What makes this violation stand out is the out-of-service rate. Of those 2,897 citations, 1,977 resulted in a vehicle being placed out of service — that's a 68.2% OOS rate. To put that in context, the all-FMCSR average OOS rate across all codes in our database is 31.4%. This code's rate is more than double that average. Even though the violation itself is not OOS-eligible by its formal designation, our inspection records show that inspectors are placing vehicles out of service in the vast majority of encounters involving this code, almost certainly in conjunction with other violations found during the same inspection.
On current activity: our data shows zero citations in the last 90 days and zero in the last 12 months. This suggests active enforcement of this specific code has gone quiet recently, but the historical record — and that 68.2% OOS rate — makes it a violation worth taking seriously whenever a full inspection occurs.
Who gets cited most
Our inspection records do not include a state-by-state breakdown for 393.100(c) in the current data snapshot, so we can't identify which states write this citation most frequently. What the data does show is that citations have been distributed across a wide range of carrier types and fleet sizes.
Among the carriers our data associates with the highest citation counts, Central Transport LLC (USDOT 661173) leads with 15 citations all-time, followed by XPO Logistics Freight Inc (USDOT 241829) with 13 citations, and Greenwood Motor Lines Inc (USDOT 63391) with 12 citations. It's worth noting that these are large, high-volume operations with enormous fleet sizes — our data shows fleets such as these accumulating citations proportional to the sheer number of inspections they undergo annually. Citation count alone does not indicate a systemic safety problem at any individual carrier.
How severe is this compared to similar codes
To understand where 393.100(c) sits in the enforcement landscape, it helps to look at other violations in the Vehicle Maintenance category. The contrast in scale is significant.
Take 393.9(a), covering inoperable required lamps: our database shows 660,737 citations for that code — more than 227 times the volume of 393.100(c) — with a 15.4% OOS rate. That lower OOS rate makes sense; a burned-out marker lamp is common and usually handled with a fix-it notice rather than a shutdown.
Look at 396.3(a)(1), the general inspection, repair, and maintenance code, which carries 236,919 citations and a 45.3% OOS rate. That rate is high, but 393.100(c)'s 68.2% OOS rate still exceeds it by more than 22 percentage points.
Or consider 393.78, windshield condition defective, with 157,894 citations and only a 0.3% OOS rate. These comparisons make clear that 393.100(c), despite its relatively modest citation volume, punches well above its weight when it comes to the likelihood of being sent to the side of the road.
How to avoid it
The vehicle make data in our records offers a useful signal. Ford vehicles lead with 209 citations, followed closely by Freightliner platforms (199 citations for FREIGHTLIN, plus 146 under the FRHT designation), and International trucks at 94 citations. These are among the most common platforms in commercial fleets, which tells you this isn't a niche problem — it can happen on any vehicle type. Here's what you can do before the wheels roll:
- Inspect every load anchor point during your pre-trip. Check that straps, chains, and binders show no fraying, kinking, or hook deformation before you leave the dock or yard. A securement device that looks marginal at origin will look worse to an inspector 200 miles down the road.
- Account for freight density and weight distribution. Heavier items stacked on top of lighter ones create a shifting risk even with adequate tie-downs. Redistribute if you can; document if you can't.
- Re-check after your first stop. Cargo settles in the first 50 miles more than at any other point in the trip. A quick walk-around at your first fuel stop or delivery takes two minutes and can prevent a shutdown.
- Know your securement count by commodity type. Different cargo types require different numbers of tie-downs based on length and weight. If you're carrying lumber, pipe, or machinery, verify your count matches what the regulations require — don't assume the shipper's load team got it right.
- Document the condition at loading. If you're picking up a pre-loaded trailer, note any visible concerns on your paperwork before accepting it. If the cargo looks like it has already shifted, refuse acceptance or get it corrected before departure.
- On Ford, Freightliner, and International platforms specifically, verify that any built-in cargo anchoring hardware — E-track slots, floor rings, or bulkhead attachment points — is fully functional and not corroded or bent. Our data shows these platforms appear most frequently in 393.100(c) enforcement events.
The bottom line is simple: if your cargo can move, it will move — and a roadside inspector will find the evidence. Build the pre-trip habit of treating securement as seriously as brakes and lights, and this citation stays off your record.