What 393.106C2-C means in plain language
This citation means an inspector found that your truck's headerboard or bulkhead is either missing entirely or not adequate to secure cargo as required by federal regulation. The headerboard (also called a bulkhead) is the vertical partition at the front of your cargo area—the barrier between your cab and the freight. Its job is to prevent cargo from shifting forward into the cab during braking or collision.
When this structure is absent or damaged enough that it cannot restrain cargo effectively, you're in violation. The regulation doesn't require you to have a headerboard for every load—only when the cargo itself or the way you've loaded it demands that protection. But when it's required and you don't have it, or when you have one that's cracked, dented, or structurally compromised, inspectors will cite you.
What our enforcement data actually shows
Across our 13 million+ inspection records, 393.106C2-C is cited relatively infrequently—ranked #928 of 3,036 FMCSR codes by citation volume. But when it is cited, it is almost always treated as a serious defect. Our inspection records show a 93.9% out-of-service rate, meaning 463 out of 493 all-time citations resulted in the truck being pulled from service until the problem was fixed. This rate is nearly three times the all-FMCSR average of 31.4%.
In the last 12 months, we documented 324 citations for this code. Over the past 90 days, inspectors cited it 76 times. The enforcement pressure appears to have peaked in June 2025, when we recorded 43 citations in a single month. Recent months (March and April 2026) show lower volumes—38 and 2 citations respectively—but the OOS rate remains consistently near 94% whenever the code appears.
Who gets cited most
Tennessee leads by a significant margin. In the last 180 days, our data shows 42 citations across Tennessee roadside inspections, with a 100% out-of-service rate. California follows with 23 citations and a 95.7% OOS rate—the only top state where some trucks were permitted to continue after citation. Florida, Ohio, Washington, Kansas, Minnesota, Colorado, Indiana, and Alabama round out the top 10, each with between 3 and 7 citations, and each maintaining a 100% OOS rate.
The variation is stark: Tennessee and California together account for roughly 65 of the 81 citations in the top 10 states over the last six months. If you operate in Tennessee, the enforcement environment for this violation is particularly strict.
How severe is this compared to similar codes
Within the Vehicle Maintenance category, 393.106C2-C stands apart for its out-of-service severity. Compare it to peer codes: 393.9(a) (inoperable required lamps) has logged 660,737 citations but only a 15.4% OOS rate. The inspection/repair/maintenance general code 396.3(a)(1) has 236,919 citations with a 45.3% OOS rate. Even slack adjuster defects (393.47E), which are brake-system critical, show 0.0% OOS rates despite 180,363 all-time citations.
In other words, when an inspector finds your headerboard inadequate, the likelihood you'll be taken out of service is roughly twice that of most other vehicle maintenance violations. Only a handful of codes in the database approach this severity threshold.
How to avoid it
Pre-trip inspection:
- Walk to the front of your cargo area and visually inspect the entire headerboard or bulkhead. Look for cracks, breaks, bent metal, missing bolts, or separated welds. If you see any compromise, report it to your carrier before loading.
- Check that the bulkhead is firmly seated and not loose at the base or sides. Tap it gently; it should not rattle or shift.
- If your truck does not have a headerboard and your cargo plan calls for one (flatbed, open-deck, or certain commodity loads), do not proceed. Ensure the structure is in place before loading.
Load planning:
- Understand when a headerboard is required for your cargo type. Do not assume you can omit it to save time or cost. Inspectors know the rules for each commodity.
- When loading, confirm that weight is distributed evenly and that nothing rests against the headerboard in a way that could stress or damage it during transit.
Vehicle maintenance:
- Our data shows that trucks with tire pressure issues (393.75A3-TAOL) and brake problems (393.47E) frequently appear in the same inspections as headerboard violations, suggesting some inspections reveal cascading deferred maintenance. Do not let equipment decay. Address brake wear, tire condition, and structural integrity as part of your routine maintenance schedule, not as emergency repairs.
- Freightliner, Peterbilt, and International trucks account for the majority of citations (83, 48, and 32 citations respectively across our database). If you operate one of these models, inspect your specific bulkhead design thoroughly and familiarize yourself with any known wear patterns or recall issues.
On the road:
- Avoid heavy braking and sudden maneuvers that could shift cargo or stress the headerboard. Even a structurally sound bulkhead can fail if exposed to extreme forces repeatedly.
- If you suspect any damage during your trip, find a safe location to stop and re-inspect before continuing. A 30-minute delay is far better than a roadside citation that pulls you out of service.