What 393.104(d) means in plain language
FMCSR 393.104(d) addresses the condition of tiedowns and cargo securement devices on your vehicle. If an inspector cites you for this code, it means they found that a tiedown or securement device is damaged, defective, or unable to perform its intended function.
In practical terms: your chains, straps, winches, cleats, or other devices used to secure cargo to the trailer are compromised. A damaged tiedown might be a chain with broken links, a strap with torn webbing, a hook that won't engage properly, or any securement component that inspectors determine cannot reliably hold cargo in place during transit. The regulation doesn't require that cargo actually shifted or fell—only that the device itself is no longer fit for purpose.
This is a vehicle maintenance violation, not a driver behavior citation. That means the responsibility typically falls on the carrier or vehicle owner to ensure equipment is serviceable before the truck leaves the facility. However, you as the driver have a pre-trip inspection obligation, and catching a damaged tiedown before dispatch protects both you and your carrier.
What our enforcement data actually shows
Across our 13 million inspection records, 393.104(d) has generated 398 all-time citations, placing it at #994 of 3,036 FMCSR codes by citation volume. In the last 12 months and last 90 days, we recorded zero citations for this code, indicating it is either being addressed effectively or inspectors are citing related securement issues under different codes.
When 393.104(d) citations are issued, inspectors place the truck out of service in 35.7% of cases. This out-of-service rate is 4.3 percentage points higher than the all-FMCSR average of 31.4%, suggesting that when damage is found, inspectors often deem it severe enough to prevent further operation until repair. Note that 393.104(d) is not an automatic out-of-service violation—256 citations resulted in a warning or written citation only, while 142 resulted in an OOS order.
Who gets cited most
Our inspection records do not include geographic breakdowns by state for this code at the level of granularity needed to reliably name the top three states. However, we can identify carriers cited under 393.104(d): Western Express Inc (USDOT 511412) leads with 3 citations across our database. Other carriers appearing in our records include White Mountain Trucking LLC, Schneider National Carriers Inc, Harbor Transportation Inc, and several others, each with 2 citations. These numbers reflect the rare citation frequency; we mention them only to note that cargo securement violations are not concentrated in any single fleet type.
Among vehicle makes cited, our data shows Freightliner (39 citations), Kenworth (25 citations), and Peterbilt (20 citations) appearing most frequently. This reflects the prevalence of these makes in trucking generally, not a quality or design problem unique to any manufacturer.
How severe is this compared to similar codes
In the Vehicle Maintenance category, 393.104(d) sits between codes with vastly different enforcement patterns. Inoperable required lamps (393.9(a)) has been cited 660,737 times with a 15.4% out-of-service rate—far more frequent and significantly less likely to trigger an OOS order. Conversely, general inspection/repair/maintenance violations (396.3(a)(1)) have been cited 236,919 times but with a 45.3% out-of-service rate, meaning inspectors deem them more serious.
The 35.7% OOS rate for 393.104(d) places it in the upper tier of severity for maintenance codes. Defective tiedowns are not the most frequently cited issue (like lamps), but when they are found, they are treated as a material safety defect roughly as often as general maintenance failures.
How to avoid it
Preventing a 393.104(d) citation is fundamentally about pre-trip inspection discipline and awareness of what makes securement equipment unfit:
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Walk around the trailer and visually inspect every tiedown before you leave the dock. Check chains for broken or bent links, look for missing or damaged hooks or D-rings, and verify that all straps are free of tears or fraying that affects grip. If it looks compromised, flag it—don't assume it will hold.
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Test tiedown engagement by hand if safe to do so. Chains should lie straight and hooks should close with resistance. Straps should be taut and not slip when you tug them. A device that feels loose or moves unexpectedly is showing wear and should be replaced or repaired before load.
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Keep your truck's securement hardware on a maintenance rotation. Tiedowns wear faster on trailers that regularly haul loads that strain them. Work with your carrier's maintenance team to identify which tiedowns are high-wear and schedule preventive replacement.
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Know the difference between "looks dirty" and "actually damaged." Road grime does not make a tiedown defective, but surface rust with pitting, bent hooks that won't close straight, or straps with UV damage that has begun to degrade the material do warrant repair or replacement.
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Document the condition of tiedowns on your vehicle inspection report (DVIR). If you notice wear during pre-trip, note it in writing. This creates a record that the carrier was on notice and protects you if the equipment later fails in transit.
Because this violation is rare (zero citations in the past 12 months), carriers and drivers who maintain equipment consistently rarely see it. The drivers and fleets who do are those cutting corners on securement maintenance or deferring repairs. Stay disciplined about the pre-trip walk-around, and you will almost certainly avoid this citation.