FMCSR 393.106C2 Q&A: Cargo Securement & Out-of-Service Risk

Yes, very likely. Across our inspection records, 393.106C2 citations result in an out-of-service order 94.9% of the time. That's far higher than the 31.4% average OOS rate across all FMCSR codes. In the last 90 days, 9 citations were issued, and 8 of them triggered immediate removal from service. Once cited, expect your truck to be parked until the headerboard or bulkhead is repaired or replaced and passes reinspection.

This violation carries a severity weight of 5 points. Your FMCSA Safety Management System (SMS) will record those points in the Vehicle Maintenance BASIC category within 30 days of the citation. The actual impact on your CSA percentile depends on how many other violations you've accumulated in the same BASIC and time window. A single citation of this type is serious, but the long-term effect depends on your full safety history.

1. Do not move the truck. You've been placed out of service.
2. Inspect the headerboard/bulkhead immediately. Determine if it's missing, damaged, or improperly installed.
3. Contact a repair facility that specializes in cargo securement equipment or structural repairs.
4. Check your lights and turn signals too. Our data shows inoperative lamps and lighting defects co-occur with this code in 7 of the last 90-day inspections—fix those before reinspection to avoid stacking violations.
5. Schedule reinspection with CVSA once repairs are complete and documented.

Yes, significantly more serious than most peers. While the broader Inoperable Required Lamp code (393.9) has a 6.9% OOS rate and Windshield Defect (393.78) is 0.3%, the 393.106C2 headerboard code triggers out-of-service orders in 94.9% of cases. Only the general Inspection/Repair/Maintenance code (396.3) comes close at 45.3%. This reflects FMCSA's zero-tolerance stance on cargo control—inadequate securement is a crash and spillage risk that cannot be ignored.

You can submit a DataQs (FMCSA Safety Management System Data Quality & Inquiry System) request if you believe the citation is factually or procedurally incorrect. However, 393.106C2 is an equipment condition violation—it must be physically verified at roadside. If the inspector documented a missing or inadequate headerboard and your vehicle was genuinely non-compliant, a DataQs challenge is unlikely to succeed. Focus on rapid repair and reinspection instead. If the documentation is unclear or the measurement was incorrect, document your evidence and file the request within the FMCSA portal.

In the last 180 days, Texas accounts for the highest enforcement volume with 18 citations and a 88.9% OOS rate. Iowa and New Mexico each had 2 citations in the same period, both at 100% OOS rates. Our all-time data shows this violation remains rare nationally—just 79 citations across 13 million inspections—but when it occurs, it is nearly always treated as an immediate safety defect. If you haul cargo in Texas, prioritize headerboard and bulkhead inspection in your pre-trip routine.

Urgent—you cannot operate. You are out of service immediately upon citation. In the last 90 days, 9 citations were issued; in May alone, 7 citations were recorded. The trend shows consistent monthly enforcement between 4 and 7 citations per month since May 2025. Because 94.9% of citations trigger OOS placement, your only path forward is immediate repair and documentation. Delaying repair extends your downtime, increases liability, and may trigger additional penalties if you operate the vehicle before reinspection clearance.

This violation attaches to the vehicle and the carrier's out-of-service record, not the driver's personal CSA record. However, your carrier's Vehicle Maintenance BASIC will be affected, which can impact the entire company's safety rating and insurance costs. If you are a solo operator (your own carrier), the violation is entirely on your Safety Management System record. Either way, rapid correction and a clean reinspection are essential to prevent escalating scrutiny at the next roadside stop.