What 393.120(d) means in plain language
FMCSR 393.120(d) requires that metal coils transported on your truck be secured according to specific securement standards. Metal coils—whether steel, aluminum, or other metals—present a unique cargo challenge because of their shape, weight, and the way they can shift during transport. The regulation exists to prevent these heavy, cylindrical loads from rolling, sliding, or falling off your trailer during normal driving conditions or emergency maneuvers.
Securing metal coils properly means using the right combination of tie-downs, blocking, or other restraints to ensure the coil cannot move in any direction—forward, backward, or sideways. The exact method depends on the coil's dimensions, weight, and how it's positioned on your trailer. Your shipper and dispatch should provide you with securement instructions, but as the driver, you're responsible for verifying before you leave the dock that the load meets federal requirements.
This isn't just a safety issue for you and other road users. A shifted or fallen metal coil can cause a catastrophic accident, and a citation for improper securement creates a safety record marker that affects your CSA score and your employability.
What our enforcement data actually shows
Across our 13 million+ inspection records, 393.120(d) has been cited only 1 time in our entire database history. In the last 12 months, we recorded 0 citations for this code, and 0 in the last 90 days. This makes 393.120(d) ranked #2796 out of 3,036 FMCSR codes by citation volume—among the rarest violations roadside inspectors encounter.
When this citation has been issued, enforcement has been severe. The one instance we have on record resulted in an out-of-service placement, giving this code a 100.0% out-of-service rate. By comparison, the all-FMCSR average out-of-service rate is 31.4%. This suggests that inspectors who cite 393.120(d) consider the cargo securement problem serious enough to remove the truck from service immediately.
Because citation volume is extremely low, this violation is rare in the field. However, that rarity does not mean the rule is unimportant—it may reflect that most carriers and drivers get metal coil securement right, or that enforcement focus in this area is light. Either way, a citation carries significant weight when it does occur.
Who gets cited most
Our inspection records show that metal coil securement citations are so infrequent that geographic and carrier patterns are minimal. The one citation we have on record was issued to O & I TRANSPORT INC (USDOT 321844). We do not have sufficient citation volume to identify top states or to show meaningful variation in enforcement across regions.
This rarity underscores an important point: if you haul metal coils, focus on getting the securement right every single time, because a citation—when issued—carries outsized significance in your safety record.
How severe is this compared to similar codes
393.120(d) sits in the Vehicle Maintenance category alongside codes that address lighting, inspection, and mechanical defects. To put its enforcement intensity in perspective:
393.9(a) (Inoperable required lamps) has been cited 660,737 times with a 15.4% out-of-service rate—far more frequent but less likely to result in immediate removal from service. 396.3(a)(1) (Inspection/repair/maintenance - general) has 236,919 citations and a 45.3% out-of-service rate, meaning general maintenance violations are cited more often and result in out-of-service placement at higher rates than lighting issues. 393.11 (Lighting devices/reflectors) shows 179,734 citations with only a 1.8% out-of-service rate—similar frequency to many maintenance codes but rarely severe enough for removal.
By contrast, 393.120(d) exists at the extreme low end of citation frequency. When it is cited, the severity (100.0% OOS rate in our data) is much higher than comparable maintenance violations. This suggests that cargo securement violations are treated as critical safety issues when they are identified.
How to avoid it
Because metal coil cargo securement is so specific, your prevention strategy should focus on pre-trip verification and communication:
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Before accepting the load, walk the trailer and visually inspect every tie-down, binder, or blocking element. Metal coils should not move when you push on them by hand. If something feels loose or improperly positioned, ask the shipper to correct it before you sign for the load.
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Know the load weight and dimensions. Heavier coils and larger diameters require more restraints. If you're unsure whether the securement is adequate for the specific coil, ask your dispatcher or the shipper's safety contact—there is no penalty for confirming compliance before departure.
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Check securement during your trip. Stop every 100–150 miles (or per your company policy) and visually inspect the load. Metal coils can settle or shift, and inspecting mid-trip gives you a chance to flag issues before an enforcement inspection.
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Document the load securement. Take photos of the load before departure if possible. If you're cited, documentation showing that the load was properly secured when you left the dock can support your defense.
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Communicate with your carrier about metal coil loads. If your company regularly hauls this cargo, work with your fleet safety manager to develop a checklist or training specific to metal coil securement. Include it in your pre-trip routine.
The extreme rarity of this citation suggests that most carriers handle metal coil securement correctly. By following these preventative steps, you'll be in that group and protect both your safety record and the safety of everyone sharing the road.