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Day-cab tractor pulling an ocean container on a chassis

What insurance does a Texas drayage carrier need to pull containers under the UIIA?

Updated . Sources for every claim are listed at the end.

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.
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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:

UIIA motor carrier insurance requirements (from intermodal.org)
CoverageUIIA requirementDetail that trips carriers up
Auto liability$1,000,000 combined single limitMust be any auto, scheduled and hired, or all owned and hired. "All owned" or "scheduled only" is not acceptable.
Hold harmless endorsementUIIE-1, CA 23 17 or TE 23 17B on the auto policyMost current edition required
General liability$1,000,000 per occurrenceNo portion may be self-insured
Trailer interchangeComprehensive, collision, fire and theft on non-owned equipmentDollar limits and deductibles are set by each equipment provider, not by the UIIA
Cargo, workers comp, employers liabilityRequired by many equipment providersLimits set by each provider in its addendum
Additional insuredEquipment providers you do business with, on auto (and GL where listed)Agent must check the additional insured box on the ACORD 22
Cancellation notice30 days; 10 days for non-paymentRenewal 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.

Drayage gaps we commonly see
RequirementWhere the gap usually is
Auto written as any auto or scheduled and hiredPolicy is scheduled only, so the UIIA rejects it
Hold harmless endorsement on the auto policyEndorsement missing or an older edition
Trailer interchange at each provider’s limitLimit meets one ocean carrier but not another provider’s addendum
Equipment providers as additional insuredAdditional insured box not checked on the ACORD 22
Continuous filingRenewal not submitted before expiration; interchange suspended
Leased owner-operatorsOwner-operator lacks non-trucking liability or physical damage on their own tractor

Leased owner-operator: who covers what

Insurance split between a motor carrier and a leased owner-operatorPrimary auto liability while under dispatch: the motor carrier carries it. Non-trucking or bobtail liability when not under dispatch: the owner-operator. Physical damage on the owner-operator's truck: the owner-operator. Motor truck cargo: usually the carrier, with deductions from the owner-operator only as the lease states. Occupational accident or workers' comp: the carrier sets the requirement and the owner-operator usually buys occupational accident coverage.CoverageMotor carrierOwner-operatorPrimary auto liabilitywhile under dispatchCarries itrequired for its authorityPays only if the leasestates a chargebackNon-trucking (bobtail) liabilitywhen not under dispatchUsually notoften asks for proofCarries itlease says who provides itPhysical damageon the owner-operator's truckUsually notnot the carrier's truckCarries itown truck, own policyMotor truck cargoon the freight being hauledUsually carries itas the carrier of recordDeductions only asthe lease spells outOccupational accidentor workers' comp for the driverSets the requirementsome cover under their WCUsually buys itoften occupational accidentUsually carries itDepends on the leaseUsually not theirs
Typical split, not a rule: the lease decides. Under 49 CFR 376.12(j), the lease must state the authorized carrier's duty to keep the liability insurance FMCSA requires, say who provides other coverage such as bobtail insurance, state the amount of any insurance charged back to the owner-operator, and spell out when cargo or property damage can be deducted from settlements. Section 376.12(h) requires every chargeback item and how it is computed to be listed in the lease. Have an attorney review the lease itself.

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:

  1. 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.
  2. Compare the highest requirement to your policy. Your trailer interchange limit has to meet the highest one among all your providers, not the average.
  3. 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.
  4. 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.
  5. 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

  1. 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.
  2. Port Houston, Terminal security and access. TWIC required for truck drivers at container terminal secure areas; Bayport and Barbours Cut gates.
  3. 49 CFR 387.9, Financial responsibility, minimum levels. Federal $750,000 floor below the UIIA $1,000,000 requirement.
  4. 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.

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