FMCSR 393.104C: Damaged Tiedown & Cargo Securement

No, 393.104C is not an out-of-service eligible violation. However, our inspection records show that even though it's not automatically OOS, inspectors placed trucks out of service in 52 instances across all-time data—a 15.4% OOS rate. This is significantly lower than the all-FMCSR average of 31.4% OOS rate, suggesting inspectors treat damaged tiedowns as fixable in most cases. You can typically continue operating while you arrange repairs, but fix the securement device promptly to avoid follow-up enforcement.

A 393.104C citation carries a severity weight of 6 points. In the CSA Safety Management Cycle, this violation counts toward your Roadside Crash Indicator and Vehicle Maintenance BASICs. Your 30-day point total depends on how many citations you accumulate in that window—a single 393.104C won't automatically trigger intervention, but repeated securement violations compound quickly. Track your point history on your FMCSA Safety Portal to monitor your standing.

Take these steps right now:

1. Document the damage. Take photos of the defective tiedown/securement device exactly as the inspector cited it.
2. Inspect related equipment. Our data shows 393.104C frequently co-occurs with inoperable lamps (393.9, 13 shared inspections in the last 90 days) and brake issues (393.47E, 9 shared inspections). Walk your entire truck.
3. Repair or replace the tiedown. This is cargo security—don't delay.
4. Keep repair records. You may need proof of correction for your carrier or insurer.
5. Review your load securement procedure. Damaged devices suggest either wear, overload, or improper application.

Not as serious as some, more serious than others. Across our 13 million inspection records, 393.104C ranks #1050 of 3,036 FMCSR codes by citation volume (337 all-time citations), placing it in the lower-mid range. Its 15.4% OOS rate sits well below the all-FMCSR average of 31.4%. Comparable violations like windshield defects (393.78) have an even lower 0.3% OOS rate, while brake issues (393.47E) are also rarely OOS. The real concern is preventing cargo shifts or loss during transit—that's a safety and liability issue, not just a points issue.

Yes, you can contest through the DataQs Roadside Defect Removal (RDR) process if you believe the violation was recorded in error or the device was not actually damaged/defective. File your dispute within 90 days of the inspection. You'll need evidence—photos of the tiedown in good condition, maintenance records, or an inspector error (e.g., misidentified vehicle). FMCSA reviews your documentation and either removes the violation or upholds it. Given that 393.104C is an equipment condition finding (not a driver behavior issue), contests succeed when you can prove the device was serviceable at the time of inspection.

Across our last 180 days of data, Texas dominates: 87 citations with a 14.9% OOS rate. Iowa, Illinois, and New Mexico each recorded only 1 citation in the same period. Texas accounted for the vast majority of 393.104C enforcement activity, likely due to higher inspection volume and aggressive cargo-haul operations. If you operate primarily in Texas, prioritize securement device maintenance—the state is clearly focusing on this violation.

Moderately urgent. Our 90-day data shows 45 citations for 393.104C—a steady but not explosive rate. However, June 2025 spiked to 33 citations, suggesting seasonal or operational upticks. The real urgency comes from cargo liability: a damaged tiedown that fails in transit can result in lost or shifted cargo, accidents, and serious liability claims far exceeding the citation itself. Repair within 2 weeks if possible. Also check your load securement procedure—repeated citations suggest a systemic issue your carrier needs to address.

This violation follows the vehicle and carrier in FMCSA's CSA system. A damaged tiedown is a truck maintenance issue, not a driver behavior issue. It lands in your carrier's Vehicle Maintenance BASIC and potentially the Roadside Crash Indicator BASIC. If you're an owner-operator, it stays on your safety record. If you're a company driver, the citation attaches to the carrier's USDOT number, though it may affect your individual record if your carrier tracks equipment failures per driver. Work with your carrier's safety manager to log the repair and close out the violation.