393.122(d) Cargo Securement - Paper Rolls: Q&A

Yes—if cited for 393.122(d), your truck is placed out of service. Across our inspection records, every instance of this violation resulted in an out-of-service placement: a 100% OOS rate. This is significantly higher than the national average OOS rate of 31.4% across all FMCSR codes. Once cited, you cannot legally operate until the paper rolls are secured in compliance with the regulation.

This violation carries a severity weight of 6 CSA points. The actual points added to your record over 30 days depends on the CSA point multiplier in effect at the time of citation. The severity weight of 6 means this is a serious maintenance violation. You should immediately contact your safety manager or an FMCSR consultant to understand the full impact on your driving record and company profile.

Immediate steps:

1. Do not operate the vehicle until cargo is resecured.
2. Inspect all paper rolls to confirm they meet the specific securement rules under 393.122(d).
3. Photograph or document the corrected securement for your record.
4. Inform your carrier's safety team and get a compliance confirmation from a supervisor.
5. Request a re-inspection if the CVSA officer offers one before you depart.
6. Keep all repair and inspection documentation for at least 12 months in case of a DataQs challenge.

This is a critical equipment violation, so swift correction is non-negotiable.

Yes. Your 100% OOS rate for 393.122(d) is far above similar vehicle maintenance violations. For comparison, inoperable lamps (393.9) have a 6.9% OOS rate, and lighting devices (393.11) a 1.8% OOS rate. The only peer code hitting an OOS rate as high is inspection/repair/maintenance general violations (396.3(a)(1)) at 45.3%. Paper roll securement is treated as an absolute safety issue, not a minor defect.

Yes, you can file a DataQs (Safety Management System Roadside Data Quality) challenge through FMCSA. Since 393.122(d) involves a specific equipment defect (paper roll securement), your challenge must show one of three things: the violation did not occur, the citation was issued to the wrong carrier or vehicle, or the violation was not observable during the inspection. Gather photos, witness statements, and securement documentation. Challenges typically take 30–60 days for resolution.

This violation is extremely rare. Across our entire database of 13 million+ roadside inspection records, only 2 citations for 393.122(d) have ever been issued. Over the last 12 months and last 90 days, there have been zero citations. It ranks #2651 out of 3,036 FMCSR codes by citation volume. If you've been cited, you are in a tiny group—and the absolute OOS placement emphasizes that inspectors treat paper roll securement as non-negotiable.

Our data shows only two carriers have ever been cited for this violation: NOVA LOGISTICS INC (USDOT 2084451) with 1 citation and 7013990 CANADA INC (USDOT 2124965) with 1 citation. Vehicle makes cited include STOU and VOLV, each with 1 citation. The extreme rarity of enforcement means this is not a widespread industry issue—it occurs in isolated cases where inspectors find unsecured paper rolls during roadside checks.

This is the highest urgency: immediate. You cannot operate under this citation. Unlike many vehicle maintenance issues that allow limited operation, the 100% OOS rate for 393.122(d) means your truck is removed from service until paper rolls are secured. Zero citations have been issued in the last 90 days, indicating this is enforced only when discovered—but when it is, the response is absolute. Fix and document before any further movement.