Michael Cavanaugh is a Partner in Holland &
Knight's
Washington D.C. office
Jameson Rice is an Associate in Holland &
Knight's
Tampa office
The Federal Maritime Commission (FMC) in March 2018 directed
Commissioner Rebecca F. Dye to initiate a fact finding
investigation (Fact Finding 28) into demurrage and detention
practices at U.S. ports. Commissioner Dye issued her Final Report on Dec. 7, 2018, concluding that
all international supply chain actors would benefit from greater
transparency, consistency and reasonableness in demurrage and
detention practices. (See Holland & Knight's alert,
"
FMC Commissioner Issues Final Report for Fact Finding 28,"
Dec. 11, 2018.)
After her Final Report, Commissioner Dye continued to meet with
industry stakeholders to refine her findings and recommendations.
On Aug. 27, 2019, the Commissioner submitted recommendations to the FMC, including:
