FMCSR 393.106(a) — Cargo Securement Front End: Q&A

No—not automatically. Across our 13 million inspection records, 393.106(a) citations resulted in out-of-service placement 27.3% of the time. This is below the all-FMCSR average OOS rate of 31.4%, meaning inspectors cited this violation but allowed continued operation in roughly 3 out of 4 cases. However, that 27.3% rate means there's still a meaningful risk of being pulled from service. The decision depends on how severe the inspector judges the cargo securement risk at the time of inspection.

393.106(a) carries a severity weight of 5. CSA applies this base weight within a 30-day rolling window—if you receive multiple violations within 30 days, the weight multiplies. So a single 393.106(a) citation is 5 points on the Vehicle Maintenance BASIC. Multiple citations in a month will compound that score. The actual impact to your CSA percentile depends on your carrier's total inspection history and other violations.

1. Document the citation. Get the inspector's written description and photos of what they found.
2. Inspect the headerboard/bulkhead. Verify whether it's truly missing, inadequate, or properly installed.
3. Repair or replace immediately. If the bulkhead is missing or damaged, fix it before your next load.
4. Request a re-inspection. If you believe the citation was wrong, ask the inspection facility for an OSV contact to arrange a follow-up.
5. File a DataQs challenge if warranted. If the finding was factually incorrect, you can contest it through the FMCSA's DataQs system within the regulatory period.

Relatively speaking, no. Among peer codes in the Vehicle Maintenance category, 393.106(a) has a lower out-of-service rate (27.3%) than general inspection/repair violations like 396.3(a)(1) at 45.3% OOS rate. However, it ranks #1763 out of 3,036 FMCSR codes by all-time citation volume, suggesting it's rarely cited. The rarity means inspectors take it seriously when they do flag it—it's not a routine write-up. Cargo securement failures can cause accidents and cargo spills, so fix it promptly.

Yes. If you believe the citation is factually incorrect, you can file a DataQs (Data Quality System) challenge through the FMCSA within 90 days of the citation. DataQs is designed for contested inspection findings—equipment defects, driver violations, and documentation errors. Submit evidence: photos, maintenance records, or proof of repair. DataQs accepts both driver and carrier submissions. Note that DataQs cannot overturn an inspector's judgment call about whether a bulkhead is "inadequate"—only whether the facts (missing, present, etc.) are wrong.

Very few. Our inspection database records 33 all-time citations for 393.106(a), with 0 citations in the last 12 months and 0 in the last 90 days. This makes it one of the rarest vehicle maintenance violations on record. The rarity reflects either strong compliance with cargo securement rules or inconsistent enforcement. Either way, if you are cited, you're in a small group—and the violation is likely to draw serious attention from your carrier or your FMCSA compliance file.

Across all citations in our data, FREIGHTLINER and VOLVO trucks account for 2 citations each. All other cited makes (HYUNDAI, KENWORTH, PETERBILT, and trailer types) have 1 citation each. The sample is too small to draw meaningful conclusions about which vehicle types are at higher risk. Cargo securement failures depend more on how a truck is loaded and maintained than on its make. Focus on proper bulkhead maintenance and inspection regardless of your equipment type.

Both. Under FMCSA CSA scoring, vehicle maintenance violations like 393.106(a) count against both the driver's record and the carrier's Vehicle Maintenance BASIC if the driver is operating under that carrier at the time of inspection. The violation appears on the inspection report in both names. That said, responsibility for bulkhead condition typically falls on the carrier's maintenance program. As a driver, you can protect yourself by conducting a pre-trip inspection and refusing to haul with defective or missing cargo securement equipment.