What 393.122(b) means in plain language
This citation means a DOT officer found that paper rolls on your truck were not secured according to the specific requirements of the Federal Motor Carrier Safety Regulations. Paper rolls—whether wound as large cylinders or in bundles—create a unique cargo securement challenge because of their shape, weight, and tendency to roll or shift during transit.
The regulation requires that paper rolls be restrained using appropriate blocking, bracing, straps, or other securement devices that prevent them from moving in any direction during normal driving, braking, or sudden maneuvers. If an officer observed rolls that could shift, roll forward, backward, or sideways, or if securing devices were missing, damaged, or improperly installed, you would be cited under 393.122(b).
This is a Vehicle Maintenance category violation—meaning the DOT treats it as a condition of the truck or cargo itself, not a procedural or paperwork issue.
What our enforcement data actually shows
Across our 13 million+ roadside inspection records, we have documented 44 all-time citations for 393.122(b). This code ranks #1670 of 3,036 FMCSR codes by citation volume, making it relatively uncommon in the national enforcement landscape.
However, the data reveals something striking: when officers cite 393.122(b), they place the vehicle out of service 97.7% of the time. By contrast, the all-FMCSR average out-of-service rate is 31.4%. This 66.3 percentage-point gap tells you that inspectors view this violation as a serious safety hazard. In the last 12 months and last 90 days, our records show zero citations for this code, indicating either improved compliance or very sporadic enforcement activity.
Of the 44 all-time citations in our database, 43 resulted in out-of-service orders and only 1 did not.
Who gets cited most
Our inspection records do not break down citations by state for 393.122(b) in sufficient volume to rank states with confidence. However, across all-time data, citations have been distributed among multiple carriers, with each of the top ten carriers appearing in our records with exactly one citation. These include SWIFT TRANSPORTATION CO OF ARIZONA LLC, COWAN SYSTEMS LLC, EVEREST TRANSPORTATION INC, and others.
Looking at the vehicle equipment side, Freightliner units account for the largest share of 393.122(b) citations in our database (11 citations), followed by Utility trailers (6 citations) and Volvo tractors (5 citations). This distribution likely reflects the prevalence of these equipment types in paper roll hauling operations rather than any inherent design flaw.
How severe is this compared to similar codes
393.122(b) sits in the Vehicle Maintenance category alongside some of the most-frequently cited regulations in the FMCSR universe. For perspective:
- 393.9(a) — Inoperable required lamps has been cited 660,737 times with a 15.4% out-of-service rate. Despite vastly higher citation volume, the OOS rate is far lower than 393.122(b).
- 396.3(a)(1) — Inspection/repair/maintenance general shows 236,919 citations with a 45.3% out-of-service rate, placing it in a middle severity range.
- 393.47E — Slack adjuster defective accounts for 180,363 citations but carries a 0.0% out-of-service rate, indicating that inspectors routinely allow trucks with defective slack adjusters to continue.
The 97.7% out-of-service rate for 393.122(b) is among the highest in the Vehicle Maintenance category and reflects the DOT's zero-tolerance approach to cargo that is not securely fastened.
How to avoid it
If you haul paper rolls or similar cylindrical cargo, implement these pre-trip and load-securing practices:
- Inspect all cargo restraint equipment before loading. Check that straps, chains, edge protectors, and blocking materials are intact, free of damage, and rated for the load weight. A missing or worn strap is an immediate red flag.
- Use proper blocking and bracing. Paper rolls must not be able to roll, slide, or shift inside the trailer. Install wooden blocks, pipe, or other rigid bracing on all sides—not just the front and back. Sideways movement during cornering or lane changes is a common failure point.
- Verify strap and chain placement. Securement devices must be routed over or through the load in a way that prevents upward movement as well as lateral or longitudinal shift. Straps placed too high or too loosely will fail under braking.
- Test the load before departing. If you can shake or move a roll by hand before the truck starts moving, the securement is inadequate. Apply hand pressure to simulate g-forces.
- Know the weight and dimensions of your load. Over-length or over-weight rolls may require additional or specialized securement that exceeds standard methods. Verify load limits with dispatch and the shipper.
- Conduct a second inspection after the first hour of driving. Cargo can settle or shift during initial acceleration and braking. Pull over safely and visually confirm that all rolls remain stationary and all devices remain tight.
- Document your securement method. Take photos of the load before departing and keep records of any securement devices used. If cited, documentation that you took reasonable precautions may be relevant in administrative proceedings.
Because 393.122(b) violations almost always result in out-of-service orders, your priority is prevention. A single citation will ground your truck and delay cargo delivery; repeated violations can trigger carrier safety investigations and elevated CSA scores.