FMCSR 393.106D: Cargo Securement Front End — Q&A

Yes—almost certainly. Across our 13 million inspection records, 393.106D results in an out-of-service order 97.2% of the time (420 out of 432 all-time citations). This rate is dramatically higher than the national average of 31.4% across all FMCSR codes. When an inspector finds your headerboard or bulkhead inadequate or missing, the truck is typically placed OOS on the spot until the defect is corrected.

This violation carries a severity weight of 5 CSA points. The final number of points in your Safety Management Cycle depends on the 30-day count: if you receive one citation in 30 days, you'll be assessed 5 points; multiple citations within 30 days accumulate. Points remain on your record for 24 months, so immediate repair is critical to avoid compounding your BASIC scores.

1. Do not move the truck. You're likely already out of service.
2. Inspect the headerboard/bulkhead with the inspector present if possible—document its condition.
3. Contact your carrier's maintenance team immediately to schedule repair or replacement.
4. Check for related violations: our data shows 393.106D often appears alongside inoperative lamps (393.9), fatigue violations (392.2RG), and other cargo securement issues (393.104B/F3)—ask the inspector for the full list.
5. Retain the citation and photograph the corrected equipment before returning to service.
6. Request re-inspection once repairs are complete if required by your state or carrier.

Yes, significantly more serious. The 97.2% out-of-service rate for 393.106D far exceeds the typical severity of related codes like 393.104B (tiedown damaged, 12 co-occurrences in our last 90 days) and general maintenance violations (396.3(a)(1) has a 45.3% OOS rate). A missing or inadequate bulkhead is treated as an immediate safety risk, not a correctable defect. Only a handful of peer codes match this enforcement severity.

Yes, you can file a DataQs (FMCSA Roadside Data Quality and Evaluation System) challenge, though success depends on the nature of the violation. If the inspector incorrectly documented that a bulkhead was missing when it was present and adequate, you have grounds to contest. DataQs challenges typically require photographic evidence, witness statements, or repair receipts showing the equipment met standards at the time of inspection. Work with your carrier's compliance team to gather evidence and submit within 90 days of the citation.

Texas leads by a wide margin: 80 citations in the last 180 days with a 93.8% out-of-service rate. Iowa follows with 14 citations (92.9% OOS), and North Carolina with 9 citations (100% OOS). These three states account for the vast majority of 393.106D enforcement. If you operate in Texas, the risk is substantially higher—ensure headerboards and bulkheads on all tractors meet inspection standards before every load.

Repair or replacement must happen before your next trip. With a 97.2% out-of-service rate, you cannot legally operate the vehicle until the defect is corrected and documented. Our data shows citation volume peaked in June 2025 (33 citations) and has remained elevated throughout 2025–2026, indicating consistent enforcement intensity. Contact your maintenance department immediately—delays in repair directly delay your revenue. Have the corrected equipment inspected by the same authority or your carrier's safety officer before resuming operation.

Both. The violation is recorded in your carrier's safety record (impacting the company's BASICS and CSA scores) and in your individual driver profile. However, the root cause—inadequate or missing equipment—is primarily a fleet maintenance responsibility. Your carrier should ensure all power units have compliant headerboards before assigning you to pull loads. If repeat 393.106D violations appear on your record, document that you flagged equipment defects; if they appear on your company's record, push for a fleet-wide equipment audit, especially of older tractors (our data shows Peterbilt units cited most frequently at 99 all-time citations).