393.122(c) Cargo Securement – Paper Rolls | Q&A

Yes. Across our 13 million inspection records, every citation for 393.122(c) has resulted in an out-of-service placement—a 100.0% OOS rate. This is significantly higher than the all-FMCSR average of 31.4%. When an inspector cites you for improperly secured paper rolls, expect your truck to be taken out of service immediately. You cannot continue operating until the cargo is corrected and re-inspected.

This violation carries a CSA severity weight of 6. The actual points added to your carrier's Cargo-Related BASIC depend on the inspection date and the 30-day point accumulation window. A single citation in isolation may generate 6 points; if multiple citations occur within 30 days, points stack. Your carrier's safety director should track your inspection date to forecast the impact on that BASIC score.

1. Stop driving. Your truck is out of service; you cannot legally operate it.
2. Secure or unload the cargo. Ensure paper rolls meet FMCSR securement standards (blocking, bracing, or tie-downs as applicable).
3. Request a re-inspection. Once corrected, contact the inspection authority or your carrier's compliance team to arrange a follow-up.
4. Document the fix. Photograph and note the corrective action for your records and your carrier's safety file.
5. Notify your carrier immediately. They need to log this for compliance tracking and CSA scoring.

Yes. The 100.0% out-of-service rate for 393.122(c) far exceeds the category average of 31.4% across all FMCSR codes. Among peer vehicle maintenance violations, most have OOS rates under 50%—for example, inoperable required lamps (393.9(a)) sit at 15.4%, and lighting devices (393.11) at 1.8%. Cargo securement is treated as safety-critical; inspectors interpret it as zero tolerance.

You and your carrier can contest the citation through the DataQS (FMCSA Crash and Roadside Inspection Outcome Data Quality System) process. To succeed, you must provide evidence that either the securement was correct at the time of inspection, or the inspector misinterpreted the securing method. Submit documentation (photos, shipping records, load plan) within the contest window. Equipment-based violations are harder to contest after the fact; focus on factual errors about what was observed.

Our data contains only 6 all-time citations for 393.122(c), making it the #2357 most-cited FMCSR code out of 3,036. The volume is too low to identify geographic hotspots. However, the citations span multiple carriers: Ozark Motor Lines, Brown Trucking Company, EOS Inc, Jacko Logistics, 5N Logistics, and Bravo Logistics each received one citation. If you operate in a region or haul paper products, review your securement procedures to prevent becoming part of this small but serious group.

Immediate. Your truck is already out of service, so urgency is built in—you cannot operate until corrected. Over the last 90 days, we have recorded zero new citations for 393.122(c), and in the last 12 months, zero citations. This rarity underscores that proper paper roll securement is routine; if you're cited, you've fallen below standard practice. Address it before your next load.

FMCSA assigns cargo securement violations (393.122(c)) to the carrier's Cargo-Related BASIC, not the driver's record. However, the driver is responsible for complying with securement standards before and during transport. Both the carrier (through training and procedures) and the driver (through execution) are accountable. A violation signals that either the carrier's securement protocol is insufficient or the driver failed to apply it correctly.