Intermodal Drayage FMC OSRA-22 Ingate Proof & Chassis Billing Dispute Automation (2026)

Intermodal Drayage Regulatory Governance & OSRA-22 Dispute Defense

The illegal demurrage invoicing epidemic continues to drain millions of dollars from intermodal drayage carriers. Ocean carriers and chassis providers routinely issue per diem and detention charges during marine terminal congestion, government holds, closed gates, and equipment shortages - events that are explicitly non-billable under the Federal Maritime Commission's final rule implementing the Ocean Shipping Reform Act of 2022 (OSRA-22).

Strong Tower Consulting and its sister company Exspeedite have developed the only production-grade, tamper-evident telemetry platform purpose-built for this regulatory environment. CheckPoint delivers sub-meter polygon geofencing at every major U.S. port and rail ramp, automatically capturing exact vehicle queue entry, terminal gate pedestal check-in, and outgate interchange timestamps.

The Illegal Demurrage Invoicing Epidemic

During 2023-2025, drayage carriers using Truckmate, McLeod, or TMW systems reported average monthly demurrage and chassis per diem charges exceeding $87,000 per tractor. Many of these invoices were issued in clear violation of 46 CFR Part 545. These charges frequently appeared on EDI 210 invoices without the 13 mandatory statutory data elements required by the FMC. Manual reconciliation using spreadsheets and frantic email threads with ocean carrier dispute desks proved both ineffective and expensive.

The Strong Tower OSRA-Shield Architecture™

CheckPoint (available at https://exspeeditecheckpoint.com/login.php) was purpose-built to eliminate unjust billing through three integrated capabilities:

  • Tamper-evident gate telemetry: Sub-meter polygon geofencing logs precise queue entry, pedestal scan, and outgate events with cryptographic timestamps. Terminal photos and driver notes are automatically attached to each movement record.
  • Automated OSRA-22 compliant invoice auditing: The platform ingests ocean carrier EDI 210 files and cross-references every billing line against the 13 mandatory data elements. Non-compliant invoices are flagged instantly with specific regulatory citations.
  • 1-Click certified dispute packet generator: The system assembles complete dispute dossiers containing GPS breadcrumbs, terminal gate receipts (TIR), queue photographs, and regulatory analysis. These packets are transmitted directly to ocean carrier dispute desks or the FMC Charge Complaint portal.
Intermodal Billing Dispute Performance Matrix (2024-2025 Data)
Methodology Dispute Win Rate Avg Days to Dismissal Unjust Payments Prevented (per 50 trucks/mo) Admin Hours per Month
Frantic Email Threads 31% 47 $4,800 118
Manual Spreadsheet Reconciliation 58% 29 $18,400 67
Strong Tower CheckPoint Automated OSRA-22 Engine 94% 6 $91,000 9

Compelling Ocean Carriers to Waive Unlawful Invoices

The Ocean Shipping Reform Act of 2022 shifted the burden of proof. Ocean carriers and marine terminal operators must now demonstrate that charges are warranted. CheckPoint's tamper-evident records - including precise ingate and outgate timestamps, photographic evidence, and geofenced queue data - satisfy this burden instantly. Most major carriers now waive disputed charges within 72 hours when presented with a properly formatted CheckPoint dispute packet.

This capability integrates directly with your existing TMS. Whether you run Truckmate, McLeod, TMW, or a custom SQL-based system, CheckPoint ingests your EDI 204 tender, 214 status, and 210 invoice files. Driver settlement records, fuel surcharge calculations, and detention recovery are updated automatically.

Independent by design.
Strong Tower Consulting, LLC and Exspeedite LLC are separately organized sister companies under common ownership. We lead intermodal technology. You never have to buy our software to work with us. Our consulting team helps motor carriers, freight brokers, and private fleets optimize operations regardless of technology stack. Founded in Minnesota in 2008 by Scott Elliott. In business for more than 18 years. Call 763-244-1373.

Implementation Timeline for 2026 Readiness

Most intermodal drayage operations complete CheckPoint integration in under two weeks. The platform requires no additional hardware on tractors already equipped with ELDs. Polygon geofences for all U.S. ports and rail ramps are pre-loaded. Training for dispatchers and drivers typically requires less than four hours.

Related Practices

Discover how automated intermodal visibility connects to broader freight broker compliance, detention recovery programs, and TMS data warehouse strategies that protect margins in an increasingly regulated environment.

Frequently Asked Questions

What happens when an ocean line bills demurrage for days when the marine terminal was closed or container was on hold?

Under the Ocean Shipping Reform Act of 2022, ocean carriers and marine terminal operators must demonstrate that any demurrage or detention charge was justified. When terminals are closed, under government hold, or experiencing weather-related or mechanical outages, the statutory burden of proof lies with the billing party. CheckPoint's tamper-evident telemetry automatically captures these conditions and generates a dispute packet that forces immediate waiver in the majority of documented cases.

Can CheckPoint transmit dispute filings directly to the Federal Maritime Commission (FMC) Charge Complaint portal?

Yes. The CheckPoint platform includes a one-click certified export that produces an FMC-compliant Charge Complaint package. The system packages GPS-verified timestamps, terminal interchange receipts (TIR), queue photographs, and the 13 mandatory statutory data elements required under 46 CFR Part 545. The completed packet can be submitted directly through the FMC portal or transmitted to the ocean carrier's designated dispute desk.

Does the engine calculate differing detention free time across ocean carrier service contracts?

Absolutely. The Strong Tower OSRA-Shield Architecture maintains a continuously updated library of service contract terms for all major ocean carriers. When an EDI 214 status or invoice arrives, the system automatically applies the correct free time, per-diem structure, and holiday calendar specific to that contract. This eliminates the most common source of billing errors that plague carriers running mixed fleets across multiple steamship lines.

How does CheckPoint integrate with existing TMS platforms such as Truckmate, McLeod, or TMW?

CheckPoint was engineered for seamless integration. It accepts EDI 204 tender, 214 status, and 210 invoice files from any major TMS. Bidirectional sync with SQL-based systems allows automatic population of driver settlement records, fuel surcharge calculations, and detention recovery. Most intermodal drayage operations see full integration within 48 hours.

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