46 CFR § 545.5 · the incentive principle
If the box could not move, the clock should not run.
Every charged day is lined up against what the terminal, the appointment system and the empty depot actually allowed that day.
Interactive
A charge window, day by day.
Gray is free time, black is charged, red is charged while the cargo or equipment could not move. Select a red day for its evidence.
ATPU 300917 2, ATPU 301144 8, ATPU 301520 5
Port of New York and New Jersey · $300/day per container
- Sep 17 Discharged from vesselEDI 315 (UV)
- Sep 18 Available for pickupTerminal TOS
- Sep 23 Terminal closed: high windsTerminal advisory
- Sep 24 Terminal closed: high windsTerminal advisory
- Sep 25 Zero import appointments offeredTerminal appointment portal
- Sep 30 Last container out-gatedGate transaction
Select a red day to see the evidence captured for it.
3 blocked of 9 charged days · $2,700 challengeable under § 545.5
What gets captured
Evidence that exists before the dispute does.
Appointments
Appointment system snapshots
Import pickup and empty return availability captured through the shift, per terminal and size/type. A day with zero slots is recorded with timestamps, not recollection.
Gates
Gate closures and dual-transaction rules
Weather, labor and system closures from terminal advisories, plus rules that blocked a dual transaction or required a specific return location.
Holds
Holds the billed party did not control
Freight, line, terminal and customs holds with set and release times, so free time is measured from true availability.
Equipment
Chassis unavailability
Pool outages and chassis shortages at the terminal or nearby depots, matched to the days a trucker could not mount the box.
GPS
Drayage geofence timestamps
Arrival and departure at terminal geofences from connected drayage platforms. A truck turned away from an empty return is proof the per diem was not the trucker's choice.
Sources reconciled
One timeline from many systems.
315
EDI container status messages, normalized per event code
Carrier milestones, normalized.
Discharge, availability, out-gate, empty return and roll events arrive from carriers in different shapes. ATAHSKIA normalizes them per container so free time can be recomputed.
Terminal TOS feeds
Availability, holds and last free day from terminal systems and community portals.
Appointment portals
Scheduled captures of slot availability by shift.
Drayage platforms
Geofence events and turn-away records from TMS connections.
Your documents
Arrival notices and delivery orders from the billing inbox.
Why it matters
Complete invoices still bill impossible days.
Part 541 makes sure an invoice says what it bills. It does not make the bill reasonable. The Commission's interpretive rule asks whether demurrage and detention served their purpose of getting cargo and equipment moving, and a charge for a day when nothing could move is hard to defend on that test.
That is why the strongest disputes pair a regulatory citation with a day-by-day record. When a dispute is denied and becomes a charge complaint under 46 U.S.C. § 41310, the carrier carries the burden of establishing that the D&D charge was reasonable, and your timeline is what it has to answer.
Milestone tracking FAQ
Where does the milestone data come from?
EDI 315 status messages from carriers, terminal operating system availability and hold data, appointment-system snapshots, terminal advisories, empty-return notices, gate transactions, and GPS geofence events from connected drayage platforms. Each event keeps its source and capture time.
What counts as a blocked day?
A charged calendar day on which the billed party could not reasonably move the cargo or equipment: terminal closed, no appointments offered, empty receiving closed for the size and type, a hold the billed party did not control, or a carrier-caused roll. The rule set is configurable per carrier and terminal.
Do we need to capture screenshots ourselves?
No. ATAHSKIA captures appointment availability and terminal notices on a schedule for every covered terminal, so the evidence exists before anyone knows it will be needed.
Does this replace our visibility platform?
It uses it. If you already run a visibility platform, connect it and ATAHSKIA reads its milestones. The difference is what happens next: blocked days are tied to specific charges and written into disputes.
More of the platform
- Learn more
OSRA Audit Engine
Checks all 20 § 541.6 elements and the 30-day issuance rule on every invoice.
- Learn more
Automated Disputes
Builds cited, evidence-backed dispute packets and tracks the carrier's 30-day reply.
- Learn more
FMC Charge Complaints
Compiles complaint dossiers under 46 U.S.C. § 41310 when a dispute is wrongly denied.
- Learn more
Carrier Scorecards
Ranks every carrier and terminal in your book by billing accuracy and credit behaviour.
Don't let your 30-day dispute window expire.
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