FMCSR 393.122 (Paper Roll Securement) — Q&A

Yes—almost certainly. Across our 13 million inspection records, 393.122 citations result in an out-of-service placement 90.9% of the time (60 out of 66 all-time citations). That's nearly three times the national FMCSR average OOS rate of 31.4%. If an inspector finds your paper rolls unsecured, your truck will likely be taken out of service until the securement issue is corrected.

A 393.122 violation carries a CSA severity weight of 6 points. This is recorded as a Vehicle Maintenance basic violation. In FMCSA's CSA scoring system, your carrier adds this weight to its 30-day rolling total for the Vehicle Maintenance BASIC. Multiple violations or violations across a 30-day period stack, so one citation may push your carrier's score higher if other Vehicle Maintenance violations were cited in the same window.

Immediate steps:

1. Stop the vehicle. Do not move the truck until cargo is re-secured or unloaded.
2. Re-secure or unload paper rolls according to FMCSR 393.122 requirements (proper blocking, bracing, and tie-downs for cylindrical loads).
3. Request re-inspection once corrected, or accept the OOS placement and arrange for a certified repair/safety inspection.
4. Document the repair with photos and invoices for your carrier's compliance file.
5. Review your securement procedures with your dispatcher to prevent repeat citations.

Do not resume operation until the inspector has verified the fix or you receive written clearance.

Yes. Our inspection records show 393.122 has a 90.9% out-of-service rate, far above the all-FMCSR average of 31.4%. Among peer Vehicle Maintenance codes, 393.122 is enforced rarely (66 all-time citations, ranked #1542 out of 3,036 FMCSR codes), but when it is cited, it is treated as a critical safety defect. By contrast, 393.9 (inoperable lamps) is cited 180,097 times with only a 6.9% OOS rate. Paper roll securement failures are treated as inherently dangerous and result in immediate service removal.

Yes. FMCSA's DataQs (DataQ Records Dispute) system allows you or your carrier to challenge a citation if the finding is factually incorrect, the violation was corrected before the roadside inspection, or the citation violates FMCSA policy. For 393.122, contestability depends on whether the inspector documented your cargo securement method in the inspection report. If the report lacks specific details (load weight, tie-down count, equipment used), you have grounds to dispute. Submit through your carrier's FMCSA portal within 90 days of the citation.

In the last 180 days, our records show 393.122 citations in two states: Iowa (1 citation, 100% OOS rate) and Texas (1 citation, 100% OOS rate). Citation volume for this violation is very low nationwide—only 3 citations in the last 12 months total—so regional patterns are minimal. This code is uncommon but carries maximal enforcement weight when cited.

Extremely urgent. The 90.9% out-of-service rate means your truck will be sidelined until the violation is corrected. Over the last 90 days, we've recorded 1 citation for this code, and in the last 12 months, only 3—enforcement is infrequent but decisive. If you receive a 393.122 citation, you cannot legally operate the vehicle for revenue until cargo securement is remedied and cleared by an official inspection. Do not delay repair or re-inspection.

Both. Vehicle Maintenance is a BASIC category in FMCSA's CSA system, meaning the violation records appear on both the driver's profile and the carrier's profile. The severity weight of 6 points is added to your carrier's 30-day Vehicle Maintenance score. However, the out-of-service action is tied to the truck; once that specific vehicle is repaired and passed re-inspection, you can resume operation. Future employment or insurance may reference the citation as part of your driving history.