FMCSR 393.120(d) — Metal Coil Securement: Driver Q&A

Yes—but only in rare cases. Across our inspection records, a truck cited for 393.120(d) was placed out of service in 1 instance out of 1 all-time citation, giving this code a 100.0% OOS rate. However, this is a single data point. For context, the national average OOS rate across all FMCSR codes is 31.4%, so metal coil securement violations are not automatically an off-road finding. The inspector's assessment of the specific securement failure will determine whether the load presents an immediate hazard.

A 393.120(d) citation carries a CSA severity weight of 7 points. Your total CSA impact depends on how many times you receive this violation within a 30-month rolling window—each instance counts independently. A single citation will add 7 points to your Maintenance BASIC category. Multiple citations within 30 months compound; the FMCSA scores your BASIC percentile based on total violations and inspections in that window. One citation is typically manageable, but repeated violations will harm your Safety Management BASIC score and increase your safety profile risk.

Take these immediate steps:

1. Document the citation — photograph the citation number, date, and violation details.
2. Inspect the load securement — verify exactly which metal coil securement rule was breached (e.g., edge protectors, straps, blocking).
3. Correct the violation — resecure or reload the coils in compliance before moving.
4. Contact your carrier/dispatcher — report the violation and confirm the truck can resume service.
5. Review your securement SOP — ensure future loads meet FMCSR 393.120 standards.
6. Keep the citation — you may need it for insurance, CSA inquiries, or if you choose to contest through DataQs.

In relative terms, 393.120(d) is rarely cited. Our inspection records show only 1 all-time citation, making it rank #2796 of 3,036 FMCSR codes by enforcement volume. Peer codes in the Vehicle Maintenance category are cited far more frequently: inoperable lamps (393.9) have 660,737 citations with a 15.4% OOS rate, and general inspection/repair violations (396.3) have 236,919 citations with a 45.3% OOS rate. The rarity of 393.120(d) enforcement suggests inspectors encounter metal coil securement issues sporadically and only cite when the breach is clear and hazardous.

Yes, you can submit a DataQs (Database Quality and Completeness) challenge through the FMCSA's SAFER system. For equipment-based violations like 393.120(d), DataQs challenges work best when you can demonstrate:

• The securement actually complied with the regulation at the time of inspection
• The inspection documented the violation inaccurately
• Photographic or maintenance records prove compliance

Since this is an objective equipment finding (not a documentation absence), you'll need concrete evidence to overturn it. Consult your company's safety team or a transportation compliance specialist to evaluate your specific case before filing.

Urgent—fix it before your next trip. Although 393.120(d) does not automatically trigger out-of-service status, the single citation in our database resulted in a placement OOS, meaning an inspector deemed the load an immediate safety hazard. Do not resume hauling the same load or similar loads until securement is corrected. Over the last 90 days, we've recorded zero 393.120(d) citations, reflecting either rarity or strong compliance. Delaying repair increases your liability and CSA risk if you're pulled over again with the same issue.

Across our 13 million+ inspection records, O & I TRANSPORT INC (USDOT 321844) has 1 citation for 393.120(d). This reflects the extremely low enforcement volume for this code. Only one carrier in our database has a recorded citation, making it impossible to identify a trend or common offender. If you work for a large fleet, the odds of your company being cited for metal coil securement issues are very low.

Enforcement is rare. Our inspection records show zero 393.120(d) citations in the last 12 months and zero in the last 90 days. The single all-time citation in our database is historical. While the regulation remains in effect and inspectors retain authority to cite it, the data shows metal coil securement is either not a widespread compliance problem or is being addressed at the carrier level before roadside detection. Stay compliant with securement standards, but do not assume heightened enforcement pressure on this specific code.