What 393.106 means in plain language
FMCSR 393.106 requires that your vehicle have an adequate headerboard or bulkhead at the front end when your cargo load demands it. A headerboard (also called a bulkhead) is a barrier—usually a solid wall or reinforced structure—mounted behind the cab or at the front of the cargo area. Its job is to prevent cargo from shifting forward into the cab during hard braking, acceleration, or collision.
You'll need this structure if your load could otherwise slide forward and create a safety hazard. Common scenarios include hauling loose freight, bricks, metal coils, or any cargo that isn't restrained by other means. If the regulation requires it and your headerboard is missing, damaged, or too weak to do its job, you're in violation.
The requirement isn't universal—it's triggered when cargo securement rules demand it. That's why inspectors focus on whether the structure matches the load you're actually carrying.
What our enforcement data actually shows
Across our 13 million+ inspection records, we have found zero citations for 393.106 in our all-time database, zero in the last 12 months, and zero in the last 90 days. Our records also show zero out-of-service placements tied to this code.
While 393.106 is eligible for out-of-service enforcement, the absence of any recorded citations or OOS actions in our dataset suggests this violation is either extremely rare in the field, handled informally by inspectors, or drivers and carriers have achieved near-universal compliance on this specific point.
This stands in stark contrast to other vehicle maintenance codes in the same regulatory family. For example, inoperable required lamps (393.9(a)) generated 660,737 citations with a 15.4% out-of-service rate, and general inspection/repair/maintenance violations (396.3(a)(1)) produced 236,919 citations with a 45.3% out-of-service rate.
Who gets cited most
Our data contains no citation records for 393.106, so we cannot identify states or carriers where this violation is concentrated. The zero-citation pattern means this analysis is not applicable.
This does not mean headerboards are irrelevant—it reflects either strong compliance or enforcement practices that fall outside our recorded citation database.
How severe is this compared to similar codes
393.106 belongs to the Vehicle Maintenance category alongside other cargo and structural requirements. To understand its place in the enforcement landscape, compare it to peer violations:
393.9(a) — Inoperable required lamps has generated 660,737 citations with a 15.4% out-of-service rate. Lighting failures are far more frequently cited, likely because they're visible and easily documented during any roadside stop.
396.3(a)(1) — Inspection/repair/maintenance (general) produced 236,919 citations with a 45.3% out-of-service rate. This broader maintenance code is the second-most cited in the category and carries the highest OOS rate, reflecting that general maintenance failures often create immediate safety risks.
393.11 — Lighting devices/reflectors accounts for 179,734 citations at a 1.8% OOS rate. Like lamps, lighting infractions are common but usually not severe enough to remove a vehicle from service.
The zero-citation rate for 393.106 suggests either that cargo securement structures are less commonly found deficient, or that when they are, inspectors address them through warnings rather than formal citations. Either way, it remains an FMCSR-required component when cargo demands it.
How to avoid it
Because headerboards are load-specific requirements, your compliance strategy depends on the freight you haul:
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Pre-trip inspection routine: Before loading any freight that might slide forward (loose items, palletized goods without edge protection, or anything taller than your cab), visually inspect the headerboard or bulkhead. Check for cracks, dents, or separation from the frame. If it's missing or clearly inadequate for the weight and size of your load, do not accept the load or inform your dispatcher before departure.
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Know your load: Work with your dispatcher or shipper to confirm whether your cargo requires front-end securement. Understand what "tight load" means for your commodity. Dense, compact cargo may not need a headerboard; loose or shifting cargo almost certainly does.
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Structural integrity: If you operate the same truck regularly, walk around the headerboard monthly. Look for rust, bolt corrosion, or flexing. A headerboard that's rusted thin or warped won't perform in an emergency stop.
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Document compliance: Take a photo of your headerboard before loading problematic freight. If you're stopped and cited, you have evidence that the structure was in place and appeared sound at the time of departure.
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Communicate with your fleet: If you drive for a carrier, report any headerboard damage immediately. Deferred repairs on this component create liability and compliance risk for everyone using that vehicle.
Because this violation is rare in enforcement data, the most likely scenario is that you'll never encounter it—but if you do haul freight that requires it, a few seconds of pre-trip attention protects your safety, your license, and your cargo.