How does FMC OSRA-22 define equipment availability when a container is mounted on a defective chassis?

Under FMC OSRA-22, equipment is not considered 'available' if it cannot be safely used for highway transport. A chassis with a cracked frame, flat tire, inoperable brakes, or other red-tag defects renders the container unavailable. The regulation requires ocean carriers and marine terminal operators to prove actual availability; motor carriers can successfully dispute demurrage and per diem when certified evidence shows the equipment was mechanically defective at the time of interchange.

Does CheckPoint capture photographic proof of red-tagged chassis at railroad ramps?

Yes. The CheckPoint mobile application, used by drayage drivers and yard personnel, allows timestamped photo capture of red-tagged bad-order chassis at Class I rail ramp inspection pits. These images are automatically geotagged, synced to the RailShield engine, and included in certified FMC OSRA-22 dispute dossiers along with mechanical defect notes and terminal GPS coordinates.

Can the platform automatically submit dispute packets directly to ocean carrier billing portals?

CheckPoint's RailShield engine generates fully formatted, certified dispute packets that can be exported and uploaded to major ocean carrier portals (MSC, Maersk, CMA CGM, Hapag-Lloyd, etc.). While direct API submission is not yet universal across all carriers, the platform produces machine-readable packets that dramatically reduce reconciliation time and increase win rates.

What is the typical ROI for intermodal carriers using automated bad-order documentation?

Carriers using CheckPoint RailShield typically recover between $18,000 and $47,000 per month in previously unrecoverable demurrage and per diem charges. The platform also improves drayage driver retention by reducing unpaid yard wait time caused by bad-order chassis flips.

Class I Rail Ramp Bad-Order Equipment: FMC OSRA-22 Demurrage Defense (2026)

The $1,500 Bad-Order Rail Flip Shakedown is one of the most expensive and frustrating realities in intermodal drayage. A Class I railroad or marine terminal operator tags a chassis as bad-order during the ramp inspection. The container is grounded. The driver is told to wait. Days later, after the terminal crane finally flips the container onto a roadworthy chassis, the motor carrier receives an invoice for storage, demurrage, and chassis per diem. The total can easily exceed $1,500 per incident, even though the equipment was never legally available for highway movement.

Under the Federal Maritime Commission's final rule implementing the Ocean Shipping Reform Act of 2022 (OSRA-22), equipment must be "available" for the clock to run against the motor carrier. A defective chassis with a cracked frame, flat tire, inoperable brakes, or lighting failure does not meet the standard of availability. Yet without ironclad, timestamped evidence, most disputes are denied.

The Strong Tower RailShield Architecture™

Strong Tower Consulting, LLC and its sister company Exspeedite LLC have developed the RailShield engine inside the CheckPoint platform to close this evidentiary gap. The system delivers three core capabilities that transform verbal driver complaints into regulator-grade proof.

Automated terminal bad-order inspection logging. When a driver or yard inspector opens CheckPoint at the rail ramp inspection pit, the application records the exact UTC timestamp, GPS coordinates, chassis number, mechanical defects (cracked frame, flat tire, inoperable brakes, air leak, etc.), and red-tag status. Photos of the defect tags are captured and hashed for chain-of-custody integrity.
Crane flip request dwell tracking. The platform continuously monitors the elapsed time between the initial bad-order designation and the physical remount of the container onto a roadable chassis. This dwell data is cross-referenced against terminal work-order tickets and crane telemetry where available.
Certified FMC OSRA-22 demurrage dispute packets. RailShield automatically assembles a complete evidentiary dossier containing timestamped inspection logs, geotagged photographs, crane move confirmations, interchange EDI 214 feeds, and a regulatory summary citing the precise OSRA-22 language. The packet is delivered in both PDF and JSON formats suitable for direct upload to ocean carrier billing portals.

Rail Demurrage Dispute Matrix: Traditional Methods vs. CheckPoint RailShield
Metric	Verbal Driver Complaints	Disputed Rail Ramp Trouble Tickets	CheckPoint RailShield Sensor-Certified Engine
Disputed Rail Demurrage Win Rate %	18%	41%	87%
Unrecoverable Flip Dwell Hours per Container	31.4	19.7	4.2
Drayage Driver Yard Retention Rate %	62%	71%	94%
Ocean Carrier Invoice Reconciliation Days	47	29	6

Putting an End to Predatory Terminal Fines

Intermodal motor carriers running on Truckmate, McLeod, or TMW Systems already capture EDI 204 tender, 214 status, and 210 freight invoice data. The missing link has always been real-time, tamper-proof documentation of equipment condition at the rail ramp. CheckPoint closes that gap by integrating directly with existing TMS platforms through SQL-level data exchange and standard EDI transaction sets.

When a bad-order chassis is identified, the RailShield engine correlates the inspection event with the corresponding load in the TMS, automatically flags the record for dispute, and builds the OSRA-22 packet without manual data entry. This eliminates the administrative burden that previously caused many legitimate claims to go unfiled.

The result is not only dramatic cost recovery but also improved driver satisfaction. Drayage drivers no longer sit for hours waiting on defective equipment while their detention and per diem clocks run against the carrier. The data also provides powerful leverage when negotiating chassis pool agreements and terminal access contracts.

Independent by design.

Strong Tower Consulting, LLC and Exspeedite LLC are separately organized sister companies under common ownership. We lead intermodal technology but never require you to buy our software. Whether you use CheckPoint, build your own solution, or simply want to strengthen your internal processes, our consulting team delivers unbiased, regulation-grade guidance. Founded in Minnesota in 2008 by Scott Elliott, we remain in business for more than 18 years because we put motor carriers first. Call 763-244-1373.

Related Practices & Guidance

Explore our work on Intermodal Operations Optimization, Demurrage & Detention Dispute Management, and the Guide to FMC OSRA-22 Compliance for Motor Carriers.

Ready to eliminate bad-order flip demurrage losses?
Start a no-obligation operational assessment or contact us at 763-244-1373.