FMC Commissioner Bentzel Urges UIIA, OSRA Harmonization

November 15, 2022

© yaniv / Adobe Stock
© yaniv / Adobe Stock

U.S. Federal Maritime Commission (FMC) Commissioner Carl W. Bentzel last week sent a letter to leaders of the Intermodal Association of North America (IANA) trade group urging harmonization of the Uniform Intermodal Interchange & Facilities Access Agreement (UIIA) contract with provisions of the Ocean Shipping Reform Act of 2022 (OSRA).

IANA provides a cross-section forum for intermodal shipping policies and as custodian to the implementation of the UIIA, a standard industry contract that governs the interchange of equipment between intermodal trucking companies and equipment providers such as ocean carriers, railroads and equipment leasing companies.

"The Federal Maritime Commission is implementing OSRA and it is vital to avoid legal conflict that the implementation of OSRA-22 should also coincide with the updating of the UIIA in order to eliminate any potential conflict on law and policy," Bentzel said.

Bentzel said he is urging IANA to consider amending the language in the UIIA concerning billing requirements to match the language in OSRA regarding the same subject. He said he is proposes IANA amend the UIIA to include the language contained in the forthcoming Detention and Demurrage Rule, as well as reflect any changes to who might be liable for payment of detention and demurrage fees.

"Close coordination is needed on this issue to ensure that we avoid needless litigation costs, or operational challenges that might arise from conflicting policy," Bentzel said.



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