What 393.104D means in plain language
FMCSR 393.104D addresses cargo securement devices that are no longer fit for purpose. If an inspector finds a tiedown strap, chain, binder, or other securement device that is cracked, torn, bent, rusted beyond safe use, or otherwise unable to hold cargo in place, you will be cited.
This isn't about cargo being poorly arranged or loose—it's strictly about the physical condition of the device itself. A frayed strap, a bent chain link, a corroded D-ring, or a broken ratchet mechanism all fall under this code. The regulation requires that every securement device be capable of performing its job when you hit the road.
What our enforcement data actually shows
Across our 13 million inspection records, 393.104D has been cited 273 times all-time, with 169 citations in the last 12 months and 38 in the last 90 days. The enforcement volume ranks this code #1118 out of 3,036 FMCSR codes—a relatively low-frequency violation in the national scheme, but one with serious consequences.
The key number: 72.2% of 393.104D citations result in an out-of-service order. That is substantially higher than the all-FMCSR average of 31.4%. When an inspector cites you for this code, the truck is likely staying put until the tiedown is replaced or repaired. In absolute terms, across all 273 all-time citations, 197 resulted in out-of-service placement and 76 did not.
Monthly data from the last 12 months shows citation activity clustering in the fall and winter months. March 2026 had the highest volume at 22 citations (18 resulting in OOS placement), while recent April data shows only 1 citation.
Who gets cited most
Our inspection records show the heaviest concentration of 393.104D citations in three states over the last 180 days:
- Texas: 75 citations, 60 out-of-service placements (80.0% OOS rate)
- New Mexico: 3 citations, 0 out-of-service placements (0.0% OOS rate)
- Illinois: 1 citation, 1 out-of-service placement (100.0% OOS rate)
Texas dominates the citation count and maintains an out-of-service rate well above the 72.2% national average for this code. New Mexico's small sample size shows no OOS placements, while Illinois's single citation resulted in roadside removal.
No single carrier appears repeatedly in our all-time data. The top carriers cited for 393.104D each have only 2 citations on record, distributed across a diverse group of both larger fleets and owner-operators. This indicates the violation is spread widely across the industry rather than concentrated in a few high-risk operations.
How severe is this compared to similar codes
Comparable vehicle-maintenance codes in the same FMCSR section show dramatically different enforcement patterns:
- 393.9 (Inoperable required lamps) has been cited 660,737 times with a 15.4% OOS rate—far more frequent but rarely resulting in out-of-service placement.
- 396.3(a)(1) (Inspection/repair/maintenance general) has 236,919 citations and a 45.3% OOS rate—more than twice as common as 393.104D but with a lower likelihood of immediate roadside removal.
- 393.78 (Windshield condition defective) has 157,894 citations but only a 0.3% OOS rate, meaning damage that doesn't obstruct vision rarely grounds a truck.
In context, 393.104D is infrequently cited but carries one of the highest out-of-service conversion rates in vehicle maintenance. When you are cited for this code, expect the vehicle to be taken out of service until the defective securement device is replaced.
How to avoid it
A damaged tiedown cannot be field-repaired to roadside-inspection standard. Prevention requires regular pre-trip inspection and disciplined replacement of worn equipment.
Pre-trip inspection checklist:
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Walk your cargo securement system before every load. Check all straps, chains, binders, and D-rings for visible damage: fraying, rust, bent metal, cracked plastic, or broken mechanisms. If you see damage, do not load. If the vehicle is already loaded and you spot damage, report it immediately and do not move.
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Replace, don't repair. Taping a torn strap or wrapping rust-damaged chain is not a fix. FMCSA inspectors will cite a damaged device regardless of tape or improvised repair. Carry spare high-quality tiedowns in your cab or tractor so you can swap a defective device roadside if needed.
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Inspect after every trip. Securement devices degrade fastest after contact with cargo, weather, and UV exposure. A strap intact at the beginning of a run can develop micro-tears by the end. Weekly deep inspection of all securement hardware is a best practice for professional drivers.
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Pay attention to vehicle make and maintenance history. Our data shows Freightliners (FRHT, 67 citations) and Kenworths (KW, 54 citations) account for the majority of 393.104D citations in our database. This reflects their prevalence in the fleet, but it also suggests older or high-mileage units may accumulate rust and corrosion on D-rings and anchor points. If you drive a unit with years on it, inspect fastening points and anchor hardware more frequently.
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Watch for co-occurring maintenance issues. When drivers are cited for 393.104D, our data shows a strong pattern of simultaneous citations for inoperable lamps (393.9, 18 shared inspections in the last 90 days) and general inspection/maintenance violations (396.3A1, 16 shared inspections). This suggests that vehicles with aged or poorly maintained securement systems often have broader maintenance backlogs. If you notice a tiedown showing wear, it's a signal to audit your entire rig for other defects.
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Document your maintenance. Keep photos or dated notes of tiedown replacement and inspection. If you are cited and believe the inspector's assessment is incorrect, your maintenance records provide the foundation for a carrier dispute or defense.
The bottom line: a damaged tiedown will ground you, often for hours. The cost of prevention—a few spare straps and 10 minutes of pre-trip inspection—is negligible compared to detention time and the CSA severity weight this citation carries.