The short version
- To interchange containers and chassis under the UIIA, a motor carrier needs $1,000,000 combined single limit auto liability, $1,000,000 per occurrence general liability, and trailer interchange coverage with limits set by each equipment provider.
- The UIIA auto policy must be written as any auto, scheduled and hired, or all owned and hired, and must carry a hold harmless endorsement (UIIE-1, CA 23 17 or TE 23 17B).
- Equipment providers you work with must be additional insureds, and the UIIA certificate is filed online only by a registered insurance agent on an ACORD 22.
- Port Houston requires drivers to present a valid TWIC at its container terminal secure areas, which is a hiring and dispatch issue as much as a compliance one.
Who this page is for
This is for Texas carriers moving ocean containers between marine terminals, rail ramps and warehouses: harbor truckers working Port Houston's Barbours Cut and Bayport terminals, carriers serving inland rail intermodal ramps, and owner-operators leased to drayage companies. See the Houston and Dallas location pages for local context.
Drayage insurance is driven by one document more than any law: the Uniform Intermodal Interchange and Facilities Access Agreement (UIIA). Ocean carriers, railroads and chassis providers that participate in it (equipment providers) interchange containers and chassis under its terms, and its insurance rules are specific.
UIIA insurance requirements
The Intermodal Association of North America publishes the UIIA insurance requirements. As of our review, they are:
| Coverage | UIIA requirement | Detail that trips carriers up |
|---|---|---|
| Auto liability | $1,000,000 combined single limit | Must be any auto, scheduled and hired, or all owned and hired. "All owned" or "scheduled only" is not acceptable. |
| Hold harmless endorsement | UIIE-1, CA 23 17 or TE 23 17B on the auto policy | Most current edition required |
| General liability | $1,000,000 per occurrence | No portion may be self-insured |
| Trailer interchange | Comprehensive, collision, fire and theft on non-owned equipment | Dollar limits and deductibles are set by each equipment provider, not by the UIIA |
| Cargo, workers comp, employers liability | Required by many equipment providers | Limits set by each provider in its addendum |
| Additional insured | Equipment providers you do business with, on auto (and GL where listed) | Agent must check the additional insured box on the ACORD 22 |
| Cancellation notice | 30 days; 10 days for non-payment | Renewal must be filed before 12:01 a.m. on the expiration date |
The filing is online and agent-only
UIIA certificates are submitted online by an insurance agent registered in the UIIA system, on one ACORD 22 covering all equipment providers. Mailed copies are not accepted. If your policy renews and the agent does not file the renewal before expiration, the system expires your coverage and you can lose interchange the same day.
Containers, chassis and trailer interchange
A drayage driver is almost always pulling a container and chassis the carrier does not own. When that equipment is damaged in your care, the UIIA makes you responsible. That is what trailer interchange insurance is for. A few points specific to drayage:
- Each provider sets its own limit. One ocean carrier's addendum may ask for a different trailer interchange limit than a railroad's. Your limit has to meet the highest requirement among the providers you actually pull for.
- The container and the chassis are both equipment. A crash can damage both, and the claim can include more than the repair bill. Read the interchange agreement for loss of use and per diem charges, and ask whether your policy responds to them.
- Street turns and storage. Equipment parked at your yard or a customer's site between moves is still in your care.
See trailer interchange vs. non-owned trailer for when each applies.
Port and ramp access
Port Houston requires truck drivers to present a valid TWIC at entry points into the secure areas of its container terminals. A TWIC by itself does not guarantee access; Port Houston also looks at business need and approval. That matters for insurance because underwriters ask who your drivers are, and a drayage carrier that hires quickly to keep up with port volume needs a driver qualification process that holds up on both fronts. See can new CDL drivers get insured.
Rail ramps run their own gate and equipment rules through the railroad's UIIA addendum. If you work both port and rail, your certificate needs to satisfy both sets of providers.
What underwriters weigh, and the common gaps
Drayage is short-haul, stop-and-go work in congested port and industrial traffic, so underwriters focus on driver turnover, how many owner-operators you lease versus employ, terminal wait-time practices, overweight container controls, and loss history. Leased owner-operators bring the owner-operator coverage split into play.
| Requirement | Where the gap usually is |
|---|---|
| Auto written as any auto or scheduled and hired | Policy is scheduled only, so the UIIA rejects it |
| Hold harmless endorsement on the auto policy | Endorsement missing or an older edition |
| Trailer interchange at each provider’s limit | Limit meets one ocean carrier but not another provider’s addendum |
| Equipment providers as additional insured | Additional insured box not checked on the ACORD 22 |
| Continuous filing | Renewal not submitted before expiration; interchange suspended |
| Leased owner-operators | Owner-operator lacks non-trucking liability or physical damage on their own tractor |
Leased owner-operator: who covers what
Before you add a new equipment provider
Most drayage certificate problems start when a carrier picks up a new steamship line, railroad or chassis pool and assumes the existing UIIA filing covers it. Walk through this before the first pull:
- Read the provider's addendum. Each equipment provider publishes its own requirements in the UIIA system, including trailer interchange limits and deductibles and whether it wants cargo, workers comp or employers liability.
- Compare the highest requirement to your policy. Your trailer interchange limit has to meet the highest one among all your providers, not the average.
- Confirm the additional insured wording. The UIIA allows blanket additional insured wording on the online ACORD form; if your policy uses scheduled additional insureds, the new provider has to be added by endorsement.
- Check the umbrella. If you want the umbrella to count toward a provider's limit, the ACORD 22 has to say which policies it sits over.
- Line up the renewal. The UIIA expires coverage at 12:01 a.m. on the expiration date, so renewal paperwork needs to be filed before then.
We can review your current UIIA filing against a new provider's addendum before you commit to the freight. Start with the review form.
Common questions
What are the UIIA insurance minimums?
Per the UIIA: $1,000,000 combined single limit auto liability with a hold harmless endorsement, $1,000,000 per occurrence general liability, and trailer interchange coverage with limits set by each equipment provider.
Why did the UIIA reject my auto policy?
The most common reasons are a "scheduled autos only" or "all owned" symbol, a missing hold harmless endorsement (UIIE-1, CA 23 17 or TE 23 17B), or equipment providers not shown as additional insureds.
How much trailer interchange do I need for drayage?
The UIIA does not set a single number. Each equipment provider lists its own limit and deductible in its addendum, so your limit has to meet the highest one among the providers you pull for.
Can I mail my UIIA certificate in?
No. The UIIA accepts certificates only online, from an insurance agent registered in its system, on one ACORD 22 covering all your equipment providers.
Do drayage drivers at Port Houston need a TWIC?
Yes. Port Houston requires truck drivers to present a valid TWIC at entry points to the secure areas of its container terminals, and a TWIC alone does not guarantee access.
Sources
- UIIA insurance requirements (Intermodal Association of North America). Auto and GL minimums, policy symbols, hold harmless endorsement, trailer interchange, additional insured, filing and cancellation rules.
- Port Houston, Terminal security and access. TWIC required for truck drivers at container terminal secure areas; Bayport and Barbours Cut gates.
- 49 CFR 387.9, Financial responsibility, minimum levels. Federal $750,000 floor below the UIIA $1,000,000 requirement.
- 49 CFR 387.7, Financial responsibility required. MCS-90 as proof of financial responsibility.
This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.
Keep reading
Coverage
Trailer interchange insurance: who pays when someone else’s trailer is damaged on your watch
Contracts and deadlines
We are leasing owner-operators onto our authority. Who insures what?
Coverage
General liability for truckers: what it covers that your auto policy does not
Locations
What do Houston trucking companies need from their insurance?
Questions
What is the difference between trailer interchange and non-owned trailer coverage?
Contracts and deadlines
The broker rejected our carrier packet because of insurance. What now?