What 393.122D-CPR means in plain language
This citation addresses the way paper rolls must be secured on your trailer. The regulation requires that paper rolls be fastened to the vehicle in accordance with specific securement standards designed to prevent them from shifting, falling, or causing instability during transport.
Paper rolls are cylindrical loads that present unique securement challenges because of their shape and weight distribution. A citation for 393.122D-CPR means an inspector determined that the blocking, bracing, straps, or other restraint devices you were using did not meet the required standard. The load may have had too much movement, inadequate tie-downs, or insufficient protection against lateral and vertical shifting.
What our enforcement data actually shows
This is an extremely rare violation in the field. Across our 13 million+ inspection records, we have recorded only 9 all-time citations for 393.122D-CPR, with just 2 citations in the last 12 months and 0 in the last 90 days. This code ranks #2230 out of 3,036 FMCSR codes by citation volume.
When this violation is cited, it almost always results in an out-of-service order. Our data shows a 100.0% out-of-service rate for this code across all time—every single citation we have on record led to the vehicle being placed out of service until the load was properly secured. This is substantially higher than the all-FMCSR average of 31.4%, reflecting the seriousness inspectors assign to cargo securement failures that create an immediate safety hazard.
The rarity of this citation suggests that most drivers and carriers handle paper roll loads correctly. When violations do occur, they trigger strict enforcement.
Who gets cited most
Our inspection records show that over the last 180 days, South Dakota accounted for 1 citation with a 100.0% out-of-service rate. The extremely low citation volume for this code means that geographic patterns are not yet pronounced in our database.
Across all time, our data shows fleets such as United Parcel Service Inc, Walbert Trucking Inc, Freight Expeditors Inc, Knight Transportation Inc, Greatwide American Trans-Freight LLC, United Transportation Services LLC, River Road Trucking LLC, Twin Carrier LLC, and Star Scott Logistics LLC each have 1 citation on record. No carrier shows a pattern of repeated violations.
How severe is this compared to similar codes
Within the vehicle maintenance category, this violation stands apart in enforcement severity. Consider these peer codes:
- 393.9(a) — Inoperable required lamps: 660,737 citations with a 15.4% out-of-service rate
- 396.3(a)(1) — Inspection/repair/maintenance general: 236,919 citations with a 45.3% out-of-service rate
- 393.47E — Slack adjuster defective: 180,363 citations with a 0.0% out-of-service rate
The 393.122D-CPR code is cited far less frequently than nearly every comparable vehicle maintenance violation, but when it is cited, enforcement is absolute. The 100.0% out-of-service rate reflects that cargo securement is treated as a non-negotiable safety requirement—there is no margin for partial compliance.
How to avoid it
Because paper roll loads are infrequent in most driver experience, prevention requires deliberate attention during pre-trip and load securement:
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Inspect all tie-down and securement equipment before loading. Check that straps, chains, or webbing have no tears, fraying, or corrosion. Verify that all attachment points on your trailer are structurally sound and not bent or broken.
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Understand the load configuration. Before securing paper rolls, confirm how many you are carrying, their diameter and weight, and how they are arranged on the trailer. Paper rolls can roll if improperly blocked; ensure they are prevented from any rotational or lateral movement.
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Use adequate blocking and bracing. Wood blocks, steel bunks, or other fixed barriers must be placed to prevent the rolls from shifting forward, backward, or side-to-side. The blocking must be secured to the trailer, not just resting against the load.
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Apply sufficient securement devices. Whether using straps, chains, or a combination, ensure adequate coverage across the load. Paper rolls typically require multiple tie-points. Straps should be snug but not over-tightened to the point of deformation.
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Verify the load after initial securing. Before departure, manually test the load by attempting to move it by hand. If the load shifts visibly or makes noise, securement is insufficient.
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Check the load en route. At fuel and rest stops, especially in the first 50 miles, visually inspect that straps are still tight, blocks remain in place, and no shifting has occurred. Vibration and road conditions can loosen initially adequate securement.
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Photograph your securement before rolling out. If an inspector cites you, photographic evidence of proper securement at load-out can support your case and demonstrate diligence.