What 393.106C2 means in plain language
A headerboard or bulkhead is a structural barrier at the front of your cargo box designed to prevent loads from shifting forward or collapsing into the cab during braking or collision. FMCSR 393.106C2 requires that this structure be present and in adequate condition whenever cargo securement rules demand it.
When an inspector cites you for this code, they found either that the headerboard was missing entirely, or it was damaged, cracked, bent, or otherwise compromised to the point where it cannot safely contain and secure cargo as intended. The regulation doesn't apply to every load—only when the cargo type and weight distribution actually require a headerboard for safe securement.
This is a structural safety issue, not a paperwork problem. If your headerboard fails, your cargo can shift forward during hard braking or a crash, destroying the cab and potentially injuring or killing you and anyone else in the vehicle.
What our enforcement data actually shows
Across our 13 million roadside inspection records, we have logged 79 all-time citations for 393.106C2. Over the last 12 months, inspectors cited this violation 52 times, with 9 citations issued in the last 90 days. This places 393.106C2 at rank #1492 of 3,036 FMCSR codes by citation volume—meaning it is enforced relatively infrequently.
However, when it is cited, the consequences are severe. Our data shows that 75 out of 79 citations (94.9% out-of-service rate) resulted in the truck being placed immediately out of service. This is dramatically higher than the all-FMCSR average OOS rate of 31.4%. In other words, if you receive a 393.106C2 citation, there is a 95 in 100 chance your truck will be stopped from operating until the headerboard is repaired or replaced.
Who gets cited most
Over the last 180 days, Texas leads all states with 18 citations and an 88.9% OOS rate (16 trucks placed out of service). Iowa and New Mexico each recorded 2 citations during the same period, with both states showing a 100% OOS rate—meaning every truck cited for this violation in those states was immediately pulled off the road. Illinois had 1 citation with no out-of-service placement.
Among carriers in our all-time database, G & R UTILITY SERVICES LLC (USDOT 4116212) appears most frequently with 2 citations. Our data shows other fleets such as SCHNEIDER NATIONAL CARRIERS INC, KENYON CONSTRUCTION INC, and EWING IRRIGATION PRODUCTS INC, each with 1 citation. This is not an indictment of any carrier; rather, it reflects the fact that this violation is uncommon enough that no single fleet dominates the enforcement statistics.
How severe is this compared to similar codes
393.106C2 exists in the Vehicle Maintenance category alongside dozens of other structural and equipment violations. Our data reveals important contrasts:
393.9(a) — Inoperable required lamps has seen 660,737 citations with a 15.4% OOS rate. While far more frequently cited, inoperable lamps are placed out of service far less often than headerboard defects.
396.3(a)(1) — Inspection/repair/maintenance general shows 236,919 citations and a 45.3% OOS rate. This code is cited roughly 3,000 times more often than 393.106C2, and its OOS rate is lower.
393.78 — Windshield condition defective accounts for 157,894 citations with only a 0.3% OOS rate. Windshield defects are rarely treated as an immediate roadside removal, whereas headerboard failures result in OOS placement in 95 of 100 cases.
The data makes clear: headerboard/bulkhead violations are treated as critical safety defects that warrant immediate removal from service.
How to avoid it
Our inspection data reveals patterns that can guide your prevention strategy:
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Perform a pre-trip visual inspection of your headerboard before loading. Look for cracks, bends, rust holes, loose bolts, or separation from the frame. If you see damage, do not load the truck. This is your first line of defense.
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Check your load securement plan before accepting cargo. Understand whether the commodity and weight distribution actually require a headerboard. If it does and you don't have one, don't take the load.
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Inspect the structural integrity of bolts and welds. A headerboard held by corroded, loose, or missing fasteners will fail inspection. Tighten bolts and verify no welds are cracked.
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Monitor lighting and turn signals on the same pre-trip walk-around. Our data shows that inoperative turn signals (393.9TS) and inoperable lamps (393.9) frequently appear in the same inspection as headerboard citations. A thorough walk-around catches both.
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Pay attention to windshield and window condition during your walk-around. Citations for windshield defects (393.78) co-occur with headerboard violations in our recent data, suggesting inspectors often conduct a full structural assessment when they find one defect.
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If you operate a FREIGHTLINER, GREAT DANE, PETERBILT, RAM, INTERNATIONAL, KENWORTH, or utility trailer, be especially vigilant. Our all-time data shows these makes account for the highest volume of 393.106C2 citations, meaning inspectors may have heightened focus on these vehicles.
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Maintain repair records and document any headerboard work. If an inspector questions whether your headerboard was properly repaired after a previous citation, documentation protects you and helps your carrier demonstrate a maintenance program.
The bottom line: a 94.9% out-of-service rate means inspectors view headerboard defects as a showstopper. Invest 5 minutes in a pre-trip inspection, and you avoid a mandatory roadside removal and the operational disruption that follows.