FMCSR 393.122(e) — Cargo Securement Paper Rolls Q&A

Yes—if you're cited for this violation, our inspection records show a 100.0% out-of-service rate for 393.122(e). This is significantly higher than the all-FMCSR average of 31.4% OOS rate. Every citation on record resulted in the vehicle being placed out of service until the paper roll securement violation was corrected. This makes it a compliance-critical defect rather than a warning-level issue.

This violation carries a CSA severity weight of 6 points. In FMCSA's safety rating system, this weight gets multiplied by inspection frequency over a 30-month rolling window to calculate your actual CSA score impact. The exact point total depends on how many other violations appear in the same inspection and your carrier's overall violation pattern, but the base severity for this specific code is 6.

Immediate steps after citation:

1. Stop hauling cargo until the paper roll securement is corrected—your truck is out of service.
2. Inspect the actual securement against FMCSR 393.122(e) rules for paper rolls (straps, chains, or devices must prevent shifting).
3. Document the repair with photos before and after.
4. Get re-inspected by roadside or certified mechanic to clear the OOS violation.
5. Review your load plan going forward—this violation prevents you from loading until it's genuinely compliant.

Do not attempt to drive the vehicle without correction.

Yes, this is severe relative to peer violations in the Vehicle Maintenance category. Across our 13 million inspection records, 393.122(e) has a 100.0% out-of-service rate, well above the 31.4% all-FMCSR average. For comparison, inoperable lamps (393.9) carry a 6.9% OOS rate, and lighting defects (393.11) only 1.8%. Cargo securement violations are treated as safety-critical because they risk load spillage and road hazards.

Yes, you can request a DataQs review (RDR) through FMCSA's portal if you believe the citation was issued in error. Cargo securement violations are fact-based (either the rolls are secured correctly or they are not), so disputes work best if: the inspector made a documentation error, misidentified your vehicle, or failed to follow inspection protocol. Technical disagreements about what "adequate securement" means are harder to overturn. File your RDR within 90 days of the citation date.

This violation is extremely rare in practice. Across our entire database of 13 million roadside inspections, 393.122(e) has only 2 all-time citations, with 0 citations in the last 12 months and 0 in the last 90 days. It ranks #2651 out of 3,036 FMCSR codes by citation volume. The rarity does not indicate it's lenient—the 100% OOS rate means inspectors cite it only when securement genuinely fails.

Our data covers only 2 all-time citations for this code. Schneider National Carriers Inc (USDOT 264184) and DHD Transportation Inc (USDOT 4276674) each received 1 citation. The vehicles involved were one Freightliner, one Great Dane, one International, and one Utility unit. This small sample reflects the overall rarity of the violation—most carriers maintain compliant paper roll securement in their loads.

Fix it immediately—do not move the truck. The 100.0% out-of-service rate means you cannot resume operations until corrected. Unlike minor lighting or documentation defects that allow limited movement, a cargo securement failure is a safety hold. The violation trend shows no citations in the last 90 days in our database, but that does not make it less urgent for you personally. Correct the securement, get re-inspected, and clear the OOS status before any further revenue miles.