What specific terminal documentation is required by the FMC to prove a chassis split lockout?

The FMC requires timestamped gate logs showing refusal due to zero bare chassis availability, digital inventory snapshots from the terminal operating system, GPS breadcrumbs confirming arrival time, and driver attestations under penalty of perjury. CheckPoint automates the capture and assembly of these records into formal dispute packets.

How does CheckPoint calculate demurrage waivers when steamship lines designate off-dock chassis yards?

CheckPoint continuously monitors both on-dock and off-dock inventory feeds. When an ocean carrier designates an off-dock yard but that yard reports zero available bare chassis at the time of the carrier's arrival, the platform freezes the demurrage and per diem clocks and generates a waiver request supported by synchronized terminal data and GPS evidence.

Can the platform automatically transmit formal OSRA dispute packets directly to ocean carrier demurrage portals?

Yes. The CheckPoint Automated FMC OSRA-22 Dispute Engine assembles complete dossiers and transmits them via API or secure portal upload to major ocean carriers including Maersk, MSC, COSCO, and Hapag-Lloyd. Transmission includes certified digital evidence bundles that meet the evidentiary standards established under the Ocean Shipping Reform Act of 2022.

What is the Phantom Equipment Billing Scam in intermodal drayage?

Many intermodal equipment providers (IEPs) continue to bill motor carriers daily chassis rental and per diem fees even when rail ramps and marine terminals have zero bare chassis available for container pickup or return. This practice violates the spirit and, in many cases, the letter of FMC regulations under OSRA-22. Strong Tower's CheckPoint solution captures real-time evidence to defeat these improper invoices.

Intermodal Chassis Pool FMC OSRA-22 Audit: Defeating Invoicing Without Available Equipment (2026)

The intermodal drayage industry continues to face a persistent and costly problem: chassis pool operators and intermodal equipment providers (IEPs) routinely invoice motor carriers for daily rental and per diem charges even when no bare chassis are physically available at the rail ramp or marine terminal. This practice, often referred to as phantom equipment billing, directly undermines carrier profitability and violates key principles codified in the Ocean Shipping Reform Act of 2022 (OSRA-22).

Strong Tower Consulting has developed a comprehensive compliance and technology architecture that allows motor carriers, whether using Truckmate, McLeod, TMW, or custom SQL-based dispatch systems, to automatically detect, document, and defeat these improper charges. The solution integrates real-time terminal data, GPS breadcrumbs, and automated FMC-compliant dispute generation.

The Phantom Equipment Billing Scam

When a drayage driver arrives at a terminal to pick up or return a container, the gate transaction frequently results in a "chassis split" or complete shut-out because the terminal chassis pool inventory is at zero. Despite this refusal, the IEP or ocean carrier still generates an invoice for chassis usage or per diem. These charges flow through the carrier's accounts payable process and are often paid because carriers lack contemporaneous evidence of equipment unavailability.

Under OSRA-22, the Federal Maritime Commission (FMC) placed clear obligations on ocean carriers and marine terminal operators to ensure equipment is available and to justify any charges with verifiable data. Carriers now have powerful regulatory tools to fight back, provided they capture the right evidence at the exact moment of refusal.

The Strong Tower OSRA Equipment Defense Architecture™

Our architecture, built around the CheckPoint platform (a sister company technology), delivers three core capabilities that transform how intermodal carriers handle chassis disputes:

Real-time terminal chassis pool inventory scraping: CheckPoint monitors live IEP depot inventories across major terminals and captures certified digital snapshots the instant a pool declares a chassis shortage or issues a shut-out. These snapshots are stored with cryptographic timestamps that meet FMC evidentiary standards.
Automated FMC Charge Complaint generator: When an invoice arrives for a date on which equipment was unavailable, the system automatically assembles a formal dispute dossier. This includes timestamped gate refusal receipts, GPS arrival breadcrumbs from the driver's ELD, terminal inventory records, and a sworn statement template ready for carrier signature.
Ocean carrier per diem clock freeze interlock: The platform automatically notifies the steamship line's demurrage portal to freeze the clock whenever an IEP bare chassis deficit prevents timely pickup or return. This prevents cascading charges that can reach hundreds of dollars per container per day.

CheckPoint integrates with existing TMS platforms including Truckmate, McLeod, and TMW through both EDI 214 status updates and direct SQL schema access to load tender (204), status (214), and freight bill (210) records. Driver settlement files are automatically updated to reflect recovered chassis and demurrage credits, preserving accurate per-mile and fuel surcharge calculations.

Intermodal Equipment Dispute Performance Matrix
Approach	Monthly Erroneous Chassis Invoices Overturned (USD)	Average Dispute Resolution (Days)	FMC Formal Complaint Filing Rate	Drayage Margin Preservation
Casual Email Complaints	$4,800	38	6%	41%
Spreadsheet Billing Audits	$21,400	19	22%	68%
Strong Tower CheckPoint Automated FMC OSRA-22 Dispute Engine	$87,600	4	91%	94%

Winning Under FMC OSRA-22 Invoicing Requirements

The Ocean Shipping Reform Act of 2022 fundamentally shifted the burden of proof. Equipment providers and steamship lines must now demonstrate that chassis were actually available at the time they billed for their use. Carriers who deploy automated monitoring tools like CheckPoint can produce irrefutable digital evidence that forces compliance under federal penalty of perjury.

This evidence includes synchronized data from terminal operating systems, GPS-verified arrival times, and real-time inventory snapshots. When presented through the FMC's formal complaint process or directly through ocean carrier demurrage portals, these records consistently result in full invoice reversals and clock resets.

Independent by Design

Independent by design. Strong Tower Consulting, LLC and Exspeedite LLC are separately organized sister companies under common ownership (separate EINs; liability firewall). We lead intermodal technology. You never have to buy our software to work with us. Our consulting team delivers process, compliance, and audit frameworks that work with any TMS. Phone: 763-244-1373.

Take Control of Your Chassis Costs

Whether you manage 25 or 250 intermodal drivers, the economics of phantom billing are no longer acceptable. The combination of OSRA-22 regulations and real-time audit technology has created a narrow window for carriers to recover millions in improper charges while simultaneously improving on-time performance.

Request a Chassis Pool Audit Assessment

Our team works with carriers running Truckmate, McLeod, TMW, and custom SQL environments. We help you integrate CheckPoint's automated radar with your existing EDI 204/214/210 workflows and driver settlement processes.