FMCSR 393.106(d): Cargo Securement Bulkhead Citations Q&A

Yes—almost certainly. Across our 13 million inspection records, 393.106(d) violations resulted in an out-of-service placement in 99.0% of cases (1,652 trucks placed OOS, 16 not). This is far above the all-FMCSR average OOS rate of 31.4%. When an inspector finds your headerboard or bulkhead inadequate or missing, the truck is almost always removed from service immediately until the issue is corrected.

This violation carries a CSA severity weight of 5 points. Your actual score in the Cargo Securement BASIC depends on how many violations you accumulate in a 30-day window—each citation adds 5 points, and the severity multiplier increases if you have multiple hits. One citation is serious; repeat violations compound quickly and can trigger intervention by your state's commercial vehicle enforcement program.

1. Do not move the truck. You are out of service.
2. Inspect the header board or bulkhead for damage, separation, or missing components.
3. Document the condition with photos before repair.
4. Contact your carrier's maintenance team and request emergency repair or flatbed tow to a certified shop.
5. Do not resume operation until a qualified mechanic certifies the securement structure is adequate and compliant.
6. Keep the inspection report and repair receipt for your records and DataQs appeal if needed.

Yes. Our inspection data shows 393.106(d) has a 99.0% out-of-service rate, placing it in the top tier of enforcement severity within the Vehicle Maintenance category. By comparison, the peer code 396.3(a)(1) (inspection/repair/maintenance general) has a 45.3% OOS rate, and 393.78 (windshield defects) is only 0.3% OOS. A missing or inadequate bulkhead is treated as a critical cargo containment failure—nearly every citation results in immediate vehicle removal.

Yes. You can file a DataQs (Crash and Roadside Data Quality System) report to challenge the citation through FMCSA's formal contestation process. DataQs accepts appeals within a set timeframe after the inspection. Because 393.106(d) is an equipment/structural condition (bulkhead integrity), the officer's observation is the key evidence. If you have documentation showing the header board or bulkhead was adequate, or if you repaired it and can prove the condition existed due to inspection error, contest it promptly. Consult your carrier's safety team or a compliance specialist to strengthen your submission.

Relatively uncommon in the broad FMCSR enforcement landscape. Across 13 million roadside inspections, 393.106(d) ranks #574 out of 3,036 FMCSR codes by total citations (1,668 all-time). However, it is taken extremely seriously: the 99.0% out-of-service rate reflects that inspectors see it as a critical safety defect. Recent enforcement is inactive—zero citations in the last 12 months and last 90 days in our database—suggesting concentrated, focused enforcement rather than routine checks.

Our all-time data shows Masters Transportation LLC (USDOT 2196945) has been cited 10 times for 393.106(d), more than any other carrier. E & R Transportation Inc, Brady's Welding and Machine Shop Inc each have 7 citations. By vehicle type, Peterbilt-based tractors (PTRB: 122 citations) and Kenworth (KW: 97 citations) dominate the citation counts, likely reflecting their prevalence in commodity hauling where bulkhead use is common. This suggests the violation is most frequent in bulk and flatbed operations.

Extremely urgent. The 99.0% out-of-service rate means your truck is grounded until the bulkhead or header board is restored to adequate condition. You cannot legally haul cargo with a compromised securement structure—it creates immediate safety and regulatory risk. The repair must be completed by a certified mechanic before the truck can resume operation. Given the near-universal OOS placement, delay is not an option; coordinate with your carrier and mechanic for same-day or next-day service.