393.118(d) Boulder Cargo Securement — FMCSR Citation Q&A

Yes, almost certainly. Across our 13 million inspection records, 393.118(d) citations resulted in an out-of-service placement 99.2% of the time—247 out of 249 all-time citations. This is far more severe than the 31.4% average OOS rate across all FMCSR violations. If you're cited for unsecured boulders, your truck will almost certainly be taken out of service until the cargo is properly secured.

A single 393.118(d) citation carries a severity weight of 7 CSA points. This is applied to the Vehicle Maintenance BASIC in your carrier's CSA score. The points are counted once at citation, then added to a rolling 30-month window and weighted by recency—the violation counts heaviest in its first 30 days, then decays. One citation alone may not trigger intervention, but combined citations can raise your BASIC score quickly.

Immediately:

1. Stop and secure the load. You will be placed out of service; the inspector will document the violation.
2. Obtain a copy of the inspection report (roadside inspection record) before you leave—it includes the specific defect noted.
3. Correct the securement according to FMCSR 393.118(d) requirements before resuming transport.
4. Keep proof of correction (photos, repair receipt, follow-up inspection if required by your carrier).
5. Notify your carrier/fleet safety manager immediately so they can document the incident and review cargo procedures.
6. Do not dispute on roadside. If you believe the citation is factually incorrect, file a DataQs challenge within 90 days of the roadside inspection.

Yes, significantly. Our data shows 393.118(d) has a 99.2% out-of-service rate, compared to 31.4% for all FMCSR violations. Among similar vehicle maintenance codes, this ranks as one of the most serious: inoperable lamps (393.9) have a 6.9% OOS rate, and lighting devices (393.11) are 1.8%. Only certain brake and structural violations approach 393.118(d)'s severity. Unsecured cargo is treated as an imminent hazard in inspection protocol.

Yes. If you believe the citation is factually incorrect or the inspector's judgment was wrong, you can file a DataQs (FMCSA's online challenge system) challenge within 90 days of the roadside inspection. Upload evidence: photos of the load before/after inspection, weight documentation, securement devices used, or witness statements. However, if the violation is a matter of equipment or procedure—the boulders were truly unsecured—the citation will likely stand. Challenges succeed when the inspector made an error in assessment or documentation, not when the violation itself is undisputed.

Across our 13 million inspection records, three carriers tie for the most 393.118(d) citations: J B Hunt Transport Inc (USDOT 80806), BFS Asset Holdings LLC (USDOT 325981), and Southeast Logistics & Transport LLC (USDOT 759891), each with 5 citations all-time. This reflects volume of operations and exposure to boulder/aggregate transport, not necessarily a pattern of lax safety. Even so, larger carriers are more visible in frequency data because they operate more trucks and move more cargo.

No active citations in the last 90 days or last 12 months in our database. The code has only 249 all-time citations on record—a very low enforcement volume compared to codes like 393.9 (660,737 citations). This suggests either strong industry compliance with boulder securement rules, or that inspectors rarely encounter this violation. When boulders are cited for improper securement, the consequence is severe (99.2% OOS rate), which may have driven compliance or reduced the prevalence of this cargo type on certain routes.

Flatbed and specialized trailers dominate 393.118(d) citations. Freightliner units account for 76 citations (all makes), followed by Peterbilt (43), Kenworth (30), and Fontaine T trailers (24). These are the platforms most likely to haul aggregates and boulders. If you operate a flatbed or open-deck trailer in aggregate, construction, or mining sectors, this violation is a real risk—ensure your securement chains, cables, and blocking meet FMCSR standards before loading.