What 393.104A means in plain language
FMCSR 393.104A cites you when a tiedown or cargo securement device is damaged, defective, or unable to perform its intended function. This is not about whether cargo is properly secured in weight or placement—it's about the condition of the physical equipment you use to secure it.
Common examples include frayed or torn straps, corroded chains, broken D-rings, bent or cracked load binders, damaged webbing, or any securing device with visible defects that compromise its ability to hold cargo in place. An inspector can cite you on the spot if they observe a tiedown that looks compromised, even if it hasn't failed.
This is a Vehicle Maintenance category violation, and importantly, it is not eligible for an out-of-service order. That means you can receive a citation and typically continue operating. However, the citation still enters your CSA safety profile with a severity weight of 6, which affects your carrier's safety rating and your own record.
What our enforcement data actually shows
Across our 13 million+ inspection records, we have documented 443 all-time citations for 393.104A, with 281 citations in the last 12 months and 61 in the last 90 days. This code ranks #961 out of 3,036 FMCSR codes by citation volume—a mid-range violation that appears regularly but is not among the most common.
Our data shows an out-of-service rate of 31.8% for this code (141 out-of-service placements against 302 non-OOS citations). This rate is essentially inline with the all-FMCSR average of 31.4%, meaning inspectors place violations of this type out of service at roughly the same frequency as violations across all codes. However, this code itself is not OOS-eligible, so those 141 out-of-service placements reflect circumstances where the inspector discovered additional violations during the same inspection.
Monthly enforcement volume has fluctuated between 12 and 37 citations over the past year. June 2025 saw the highest activity at 37 citations, while April 2025 recorded the lowest at 12. The trend in the last 90 days shows steady activity, suggesting this violation remains a consistent focus during roadside inspections.
Who gets cited most
Our inspection records show regional concentration in enforcement. Texas leads by a significant margin with 77 citations over the last 180 days, resulting in a 33.8% out-of-service rate on those stops. North Carolina follows with 24 citations and a 33.3% OOS rate—nearly identical severity. Illinois ranks third with 9 citations but shows a lower 22.2% OOS rate, suggesting inspectors may be citing the violation without discovering compounding defects.
New Mexico and Iowa each recorded only 3–5 citations in the same period, with zero out-of-service placements, indicating either lower enforcement focus or better compliance in those regions.
Our data shows fleets such as Johns Premier Transit LLC (5 all-time citations) and Camara Xpress LLC (4 citations) appearing in the records. This is not an indication of systematic negligence—it reflects the volume of inspections these carriers encounter and the natural frequency of minor securement equipment defects across large fleets.
How severe is this compared to similar codes
In the Vehicle Maintenance category, 393.104A sits well below some of its peers in citation volume. The most-cited peer code, 393.9 (Inoperable required lamps), has generated 660,737 citations all-time with a 15.4% OOS rate—far exceeding both the citation count and the out-of-service frequency of damaged tiedowns. Another major peer, 396.3(a)(1) (Inspection/repair/maintenance—general), shows 236,919 citations and a 45.3% OOS rate, reflecting more serious maintenance deficiencies.
By comparison, 393.11 (Lighting devices/reflectors) has 179,734 citations but only a 1.8% OOS rate, suggesting that lighting violations are often cited as violations of record rather than safety-critical stops. The 31.8% OOS rate for damaged tiedowns falls between these extremes, indicating that when this violation is found, it frequently co-occurs with other defects serious enough to warrant removal from service.
How to avoid it
Preventing a 393.104A citation requires attention to your cargo securement system before every trip and between loads.
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Inspect tiedowns and chains before each load. Run your hands along straps, webbing, and chains to feel for tears, fraying, corrosion, or brittleness. Replace or repair any device that shows visible damage or doesn't feel intact. This is a 5-minute task that eliminates the citation risk entirely.
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Check D-rings, load binders, and fastening points. Ensure all anchor points on your vehicle are not bent, cracked, or corroded. Tighten any loose bolts and replace any damaged hardware. Inspectors pay close attention to these because they are the foundation of secure cargo.
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Rotate out damaged equipment immediately. Don't tape, glue, or jury-rig a broken strap or chain. Carry spare tiedowns of each type you use, and swap out worn equipment before it fails an inspection.
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Pair this check with a general vehicle walk-around. Our inspection records show that 393.104A frequently co-occurs with lighting violations (393.9: 21 shared inspections in the last 90 days) and brake defects (396.3A1BOS: 6 shared inspections). When you inspect tiedowns, also verify that all lamps are functional and brake systems are sound. A single roadside stop often uncovers multiple violations, so addressing one category of defects together is efficient.
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Document your pre-trip inspections. Keep a log or photo record showing that you visually inspected securement equipment. This creates a defense if a citation is issued and supports your safety culture if audited.
The good news is that 393.104A is entirely preventable through routine maintenance. Unlike violations tied to driver behavior or compliance complexity, a damaged tiedown violation reflects only the condition of equipment under your direct control.