What 393.122(e) means in plain language
When you haul paper rolls, they must be secured in your truck bed or trailer according to specific Federal Motor Carrier Safety Regulation requirements. A citation for 393.122(e) means a roadside inspector found that your paper rolls did not meet those securement standards.
Securing paper rolls correctly prevents them from shifting, tipping, or falling during transit. Paper rolls are heavy, cylindrical cargo that can cause serious accidents if they come loose. The FMCSR rules for paper rolls are detailed and specific—they cover how rolls should be positioned, what restraint devices you need, and how those devices must be applied to keep cargo stable during normal driving, braking, and turning.
If an inspector cites you for this code, it means one or more of those securement rules was not followed. This is not a judgment about your intent; it's about whether the cargo was actually secured in the way the regulation requires.
What our enforcement data actually shows
Across our 13 million inspection records, 393.122(e) is an extremely rare citation. All-time, we show only 2 citations for this code in the entire dataset, with 0 citations in the last 12 months and 0 in the last 90 days. This makes 393.122(e) the #2651-ranked FMCSR code out of 3,036 by citation volume.
When this code has been enforced, the out-of-service rate was 100%—both of the 2 citations resulted in the vehicle being placed out of service. To put that in context, the all-FMCSR average out-of-service rate is 31.4%, so 393.122(e) has been treated as a critical defect in every case we've recorded.
The scarcity of citations suggests that either paper-roll cargo is not common in most fleets, or that most drivers and carriers who haul it are securing it correctly. However, when a violation is found, inspectors are taking it seriously.
Who gets cited most
Our records do not include a breakdown by state for 393.122(e) because the citation volume is too low to provide meaningful state-level distribution. The two all-time citations came from carriers including Schneider National Carriers Inc (USDOT 264184) and DHD Transportation Inc (USDOT 4276674), each with 1 citation in our database.
The vehicles cited were diverse—one Freightliner, one Great Dane trailer, one International, and one utility trailer. This diversity suggests that paper-roll cargo violations are isolated incidents rather than a systemic issue tied to specific makes, models, or carrier fleets.
How severe is this compared to similar codes
393.122(e) sits in the Vehicle Maintenance category alongside many other cargo and equipment codes. To understand its relative severity, consider these peer violations from the same category:
393.9(a) – Inoperable required lamps has been cited 660,737 times with a 15.4% out-of-service rate. Lamp violations are far more common but result in OOS placement less often than 393.122(e).
396.3(a)(1) – Inspection/repair/maintenance general has 236,919 citations with a 45.3% out-of-service rate. This broader maintenance category is cited 118,000 times more frequently than 393.122(e), and is placed out of service at higher rates.
393.47E – Slack adjuster defective has logged 180,363 citations with a 0.0% out-of-service rate. Despite being a brake-related defect, it rarely results in OOS placement, unlike 393.122(e), which has a 100% OOS rate in our records.
The extreme rarity of 393.122(e) citations combined with their universal OOS outcome suggests that inspectors do not flag this violation lightly, and that when they do, it reflects a serious securement failure.
How to avoid it
If your fleet operates paper-roll cargo, incorporate these steps into your pre-trip and cargo-loading process:
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Inspect load placement before departure. Verify that each paper roll is positioned according to the securement rules specific to your trailer type. Know where rolls should sit (side-by-side, end-to-end, or in a specific orientation) and check that they are in the correct arrangement.
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Use the right restraint devices. Make sure you have the correct number and type of straps, chains, or binders for your load. Paper rolls are heavy; undersized restraints can fail during transit. Count them, inspect them for damage, and use the correct tie-down points.
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Test restraints before rolling. Tug on each strap or chain by hand before you leave the loading dock. A restraint that feels loose or wobbles is not secure. Reposition the load or add restraints if needed.
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Know the rules for your trailer. Different trailer types (van, flatbed, drop-deck) have different securement rules for paper. If you switch trailers, confirm the securement method is correct for that equipment. Ask your dispatcher or safety manager if you are unsure.
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Request a mock inspection. Ask your fleet to conduct a pre-roadside inspection of your fully loaded trailer using the same checklist a DOT officer would use. Feedback before you leave the yard beats a citation at the roadside.
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Document your load. Take photos of the secured load from multiple angles. If a citation is later disputed, photographic evidence of proper securement at departure can support your case.