Drayage: What It Takes to Pull Containers
Short miles, high turns, and a completely different set of counterparties. Drayage is the one sector where the freight, the trailer and the appointment are all controlled by someone who is not your customer.
What drayage is
Drayage is the short-haul move that connects an ocean or rail terminal to somewhere else: a warehouse, a transload facility, a rail ramp, a customer's dock. The distances are short — often well under a hundred miles — and the work is measured in turns per day rather than miles per week.
That changes the economics entirely. In over-the-road trucking your cost per mile is the number that matters. In drayage, your revenue depends on how many moves you complete, and your costs are dominated by time spent waiting at gates that you do not control. A carrier that thinks in cents per mile will misprice drayage in both directions.
The credentials
The UIIA
The Uniform Intermodal Interchange and Facilities Access Agreement is the standard industry contract governing the interchange of equipment between intermodal trucking companies and equipment providers — ocean carriers, railroads and chassis leasing companies. It is administered by the Intermodal Association of North America, which reports that roughly 95 percent of North American equipment interchanges are managed under it, with around 13,000 participating trucking companies.
Without it, you would need a separate interchange contract and separate insurance filings with every ocean carrier and railroad you touch. With it, you sign once and then get approved individually by each equipment provider you want to work with.
The application requires insurance documentation on the prescribed forms — ACORD 22 certificates — meeting the UIIA insurance requirements. Note that individual equipment providers can impose requirements above the UIIA baseline, and some do. Check the specific ones you intend to work with before you buy a policy.
A TWIC
The Transportation Worker Identification Credential is required for unescorted access to secure areas of maritime facilities under the Maritime Transportation Security Act. TSA issues it after a security background check. It is valid for five years. The fee is $128 for a new applicant, $105.25 at the reduced rate for applicants who already hold a hazardous materials endorsement or a FAST card, and $60 for a replacement card.
Apply early. The background check and the appointment system take time, and no port will let you in without it.
A SCAC code
The Standard Carrier Alpha Code is the four-letter identifier used throughout intermodal and ocean systems, issued by the National Motor Freight Traffic Association. UIIA registration requires one. It renews annually.
Port-specific requirements
Individual ports and terminals add their own: registration in a terminal appointment system, an RFID tag on the tractor, emissions rules on the truck itself in some jurisdictions, and sometimes a separate port ID. These vary port by port and change, so ask the terminals you plan to serve rather than relying on a general guide.
The chassis problem
In domestic trucking you own or lease your trailer. In drayage you generally do not own the chassis. It belongs to an intermodal equipment provider, comes from a pool, and is interchanged to you for the duration of the move.
Three consequences:
- You are responsible for its condition while you have it. A roadside inspection on a chassis with defective brakes or lighting is an inspection on your record. 49 CFR 396.9 applies to intermodal equipment as well as to motor vehicles, and the pre-trip on a pool chassis is not a formality — it is the only chance you get.
- Chassis usage costs money, in daily rental or pool fees, and those days accumulate while a container sits waiting for an appointment.
- Damage disputes are common, which is the argument for photographing every chassis at pick-up and at return, every time, without exception.
Detention, demurrage and per diem — three different things
| Charge | What it is for |
|---|---|
| Demurrage | Cargo sitting inside the terminal beyond the free time allowed |
| Detention (per diem) | Equipment kept outside the terminal beyond the free time allowed |
| Driver detention | Your driver and truck waiting at a facility — the ordinary trucking accessorial |
The first two are ocean-industry charges that can run into serious money on a container nobody moved. The third is the one you invoice for. Confusing them in a conversation with a customer is a quick way to lose the argument. Driver detention is covered separately here.
The FMC billing rule, and what a court did to it
The Federal Maritime Commission's Demurrage and Detention Billing Requirements rule took effect on May 28, 2024, at 46 CFR Part 541. Two provisions are worth knowing:
- A 30-day invoicing deadline. Vessel-operating carriers and marine terminal operators must issue an invoice within 30 calendar days of the date charges were last incurred; non-vessel-operating common carriers within 30 days of the date they were themselves invoiced.
- Required invoice contents, and a dispute window. The invoice must contain specified information, and a billed party has at least 30 calendar days to request fee mitigation, refund or waiver, with the billing party required to attempt resolution within 30 days unless both sides agree otherwise. An invoice missing required information eliminates the payment obligation.
On September 23, 2025, the U.S. Court of Appeals for the D.C. Circuit vacated one provision — 46 CFR 541.4, which restricted who could be billed to the person for whose account the billing party provided ocean transportation or storage, or the consignee. The rest of Part 541 was upheld and remains in force. The court left the Commission free to revisit the billed-party question in a future rulemaking with a fuller justification.
Why this matters to a motor carrier. The vacated provision was the one that most directly limited whether a trucker could be billed for demurrage and detention. With it set aside, who may be invoiced is governed by the underlying contracts and by the Shipping Act's general prohibitions rather than by that rule. If you are being invoiced for these charges, the terms you signed matter more than they did — read the interchange agreement and the terminal tariff, and get advice before paying an invoice you believe is not yours.
How the money works
Drayage is usually priced per move rather than per mile, with accessorials layered on: chassis usage, pre-pull, drop and hook, storage, congestion, fuel. A great many disputes in the sector are about whether an accessorial was earned, which makes the rate confirmation and the tariff the documents that decide your margin.
The two things that kill a drayage operation are both time, not distance:
- Turn time at the terminal. A driver who completes three turns a day earns more than one who completes one and a half, on identical rates and near-identical fuel. Terminal congestion is therefore a direct revenue problem, not an inconvenience.
- Equipment sitting. A container on a chassis in your yard waiting for a delivery appointment is accruing charges and occupying a chassis you are paying for.
Cost per mile still matters, but for drayage the number to model is cost per turn, and cost per hour of driver and truck time. Our cost per mile calculator gives you the cost base; converting it to a per-turn figure is a matter of your own average turn length and turns per day.
Is it a sensible place to start?
Arguments for it: the driver goes home every night, which changes hiring completely; the miles are short, so fuel and wear are lower per day; and the freight is tied to ports and ramps rather than to a broker relationship you have to build from nothing.
Arguments against: the entry paperwork is heavier than any other sector on this site, you are exposed to congestion you cannot control, you inherit responsibility for equipment you do not own, and the demurrage and detention exposure is real money. It also concentrates you geographically, which is fine until that port has a bad year.
The honest summary is that drayage rewards operators who are good at scheduling and terrible for operators who are good at driving. If the appointment system, the chassis logistics and the invoice disputes sound like your kind of work, it is a solid sector. If they sound like overhead, it is not.
Related reading
- Detention and accessorials — what waiting costs, and documenting it.
- Finding freight as a new authority.
- Out-of-service orders — including intermodal equipment.
Sources
- Uniform Intermodal Interchange and Facilities Access Agreement — Intermodal Association of North America.
- Transportation Worker Identification Credential — Transportation Security Administration, for validity and fees.
- Final rule on detention and demurrage billing practices — Federal Maritime Commission.
- U.S. Court of Appeals issues decision on demurrage and detention billing practices — Federal Maritime Commission, on the September 23, 2025 vacatur of 46 CFR 541.4.
- 49 CFR 396.9 — inspection of motor vehicles and intermodal equipment in operation.
General information, not legal advice. Regulations change; confirm current requirements with the agency before acting.