CCSB Contact: Larissa A. Franklin Telephone (703) Item Description Class

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1 Re: Ice Making Machines Item CCSB Contact: Larissa A. Franklin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Ice Making or Refrigerating Machinery or Machines: subject to item Machines, ice making, see Note, item , in boxes, crates or Packages 107, 1082, 2163, 2370 or NOTE Applies on self-contained ice making machines with or without storage bins or dispensers. Package 2163 SHIPPING CONTAINER: Box Inverted, half-slotted, doublewall corrugated fiberboard container testing 350 pounds. Liner Full-height tube and full dimension top pad of corrugated fiberboard testing 200 pounds, coated with nonabrasive material where in contact with finished surfaces. Corner Posts Four L-shaped cornerposts constructed of nominal 1 x 4 lumber placed outside of liner with two cross-members of same material nailed thereto on top and four cross members framing (joining) all cornerposts at bottom. Base Article must be through bolted to a wooden pallet having a top face of ¾ inch thickness. Box must be securely attached at bottom to pallet on all four sides and vertically strapped to pallet with 2 metal straps. GROSS WEIGHT: Not to exceed 750 pounds. All fiberboard must meet the requirements of Item 222, Secs. 2 and 3. Package 2370 SHIPPING CONTAINER: Body Half-slotted container (HSC) of corrugated fiberboard with top outer flaps overlapping not less than three inches. Fiberboard must comply with Item 222, Secs. 2 and 3 except that for gross weights stipulated, boxes must be constructed and must test as indicated below: Maximum Weight of Box and Contents (pounds) Type of Box Minimum Test of Fiberboard Mullen or Cady Test (pounds per square inch) 290 HSC 350 doublewall 440 HSC 500 doublewall 2018 National Motor Freight Traffic Association, Inc. Subject 2, Page 1 of 7

2 Present Classification Provisions Concluded Package 2370 (Continued) Base Article must rest on a five-piece wood frame full dimension of container of lumber not less than 3 /4 inch thick, with a combined cross sectional area not less than nine square inches. Interior Forms A clearance of 3 /4 inch must be maintained on side-walls and one inch on top by full-height L-shaped corner posts made of built-up doublewall corrugated fiberboard testing 275 pounds if gross weight of product is under 290 pounds. If gross weight of product exceeds 290 pounds corner posts must be made of 350 pound doublewall corrugated fiberboard. If length of box exceeds 34 inches and clearance at front of article is less than three inches, front and top of article must be further protected by corrugated fiberboard doublewall forms or expanded polystyrene foam of at least 1.25 pound density of a proper thickness to maintain the specified clearances. Closure Top flaps must be closed with hot melt adhesive glued over at least 75 percent of the area of contact. Container must be attached to a wood skid by stapling with 16 gauge staples, with a maximum one inch crown and 3 /4 inch leg, spaced no further than six inches apart. Package 2481 SHIPPING CONTAINER: Unit must be through-bolted to wood base, utilizing full-height corner posts and top cap, unitized by shrink wrap. Cap 200 pound test doublewall corrugated fiberboard having a flange depth of not less than four inches. Corner Posts and Pads Full-height solid fiberboard corner posts must be positioned at each vertical corner of article to maintain a minimum 1 1 /2-inch clearance. Vertical pads of not less than 4 inches in width must be positioned so that no aperture will exceed 18 inches in width. Film Wrap Article and shipping container components must be enclosed within polyethylene shrink wrap of 4-mil thickness. Base Unit must be through-bolted to 2-way-entry wood base. Subject 2, Page 2 of National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Ice Making or Refrigerating Machinery or Machines: subject to item Machines, ice making, see Note, item , in boxes, crates or Packages 107 or 1082, see Notes, items A-NEW and B-NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 but less than Sub 3 10 or greater NOTE No Change. A-NEW NOTE Articles must be protected by packing forms or other packaging materials necessary to afford adequate protection against damage. B-NEW NOTE Articles tendered for shipment on lift truck skids, pallets or platforms must be securely fastened to and must not overhang the edges of the lift truck skid, pallet or platform deck. Cancel; no further application. Cancel; no further application. Cancel; no further application. Analysis Package 2163 Package 2370 Package 2481 Research Project 1329 This proposal is based on information developed through Research Project 1329, which was initiated in December of 2017 to investigate the transportation characteristics of ice making machines, as described in item History of Provisions Provisions for ice making machines, as named in item , and Note, item , were established as a result of action taken on Docket 127, Subject 5 (January 1967) and first appeared in Supplement 16 to NMFC A-9, effective November 29, As a result of action taken on Docket , Subject 20 (February 2005), the provisions were moved from the Coolers Group to the Machinery Group, and the present language of Note, item was 2018 National Motor Freight Traffic Association, Inc. Subject 2, Page 3 of 7

4 established. These changes first appeared in Supplement 2 to NMF 100-AE, effective April 30, The provisions have remained unchanged to the present. About Ice Making Machines Ice making machines are electrically powered, stand-alone appliances that freeze water into ice. They come in a variety of sizes and can be found in either commercial or household settings. Ice making machines may also be equipped with dispensers or storage bins. Examples of the involved commodities are depicted below. Transportation Characteristics Density The information of record includes 33,137 density observations submitted by a carrier and shippers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 1.08 to pcf, with an overall average density of 8.55 pcf. The data can be divided into three density groupings of less than 6 pcf, 6 but less than 10 pcf, and 10 pcf or greater. When evaluated on the basis of these three density groupings, the ranges and averages shown in the table below are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling Ice making machines are commonly shipped in fiberboard boxes, which may or may not be secured on lift truck skids or pallets. Products tendered in boxes not secured on lift truck skids or pallets may be more difficult to handle due to the lack of an access area for the forklift tines. These products may also be tendered secured on lift truck skids or pallets with a fiberboard cover or wrapped in plastic film with fiberboard corner posts and top caps. Ice making machines tendered in either manner may require extra care and attention to prevent damage. Examples of these typical forms of packaging are depicted on the following page. 1 The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it is not tied to any particular research project, nor does it target any particular product category. Carriers that choose to participate in the study periodically submit shipment data captured through their respective freight auditing programs. The data is identified by NMFC item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. Subject 2, Page 4 of National Motor Freight Traffic Association, Inc.

5 Ice making machines are prone to damage, including cosmetic damage, and frequently have precautionary markings or shipper instructions, such as Fragile, This Side Up, Handle With Care, Do Not Clamp From Side, Do Not Load From This Side, Do Not Tilt and Keep Dry. Such markings or instructions are indicative of the need for the carrier to handle these products with extra care and attention. Stowability Although most ice making machines tendered for shipment appear to have a flat load-bearing surface on which compatible freight may be loaded, some units are marked with stacking restrictions, and carriers should use caution when loading heavier freight on top. Additionally, some ice making machines have storage bins or other parts separately packaged and secured from the main unit, as shown on the right. The configuration of this handling unit would not allow for stacking of other freight. Ice making machines may also provide some lateral support for compatible adjacent freight; however, given that ice making machines are typically constructed of thinner gauge metal, they are more prone to dents and punctures from freight with which stowed. Furthermore, carriers have noted that many ice making machines are tendered with little or no interior packaging, which makes an already vulnerable product that much more susceptible to damage. Moreover, ice making machines tendered wrapped in plastic film not only lack the proper interior packaging, but also have insufficient exterior packaging to protect the freight in the less-than-truckload environment. Thus, extra care, attention and consideration will have to be taken to load only compatible freight on top of or adjacent to ice making machines National Motor Freight Traffic Association, Inc. Subject 2, Page 5 of 7

6 Liability These commodities are not perishable, unusually susceptible to theft, likely to damage freight with which stowed, nor are they hazardous in nature. However, regardless of how they are packaged, these products are susceptible to damage during transit. One carrier reported a claims ratio of 1.23% between January and July 24, 2018 and a claims ratio of 2.60% between January and November 30, A second carrier reported that in 2016 and 2017 it had a total of nine damage claims and paid out over $6,700. That carrier also mentioned that ice storage bins shipped with but packaged separately from the machines are easily damaged due to their lightweight construction. A third carrier stated its experience with these units has proven disastrous, as evidenced by one customer account having a 95.14% claims ratio in This information is based on eight claims, and the carrier reported it is no longer moving freight for this customer. That carrier also reported it had a second customer account that had claims ratios of 4.56% and 2.98% in 2016 and between January and November 30, 2017, respectively. All of these claims filed were for damage. A fourth carrier reported that ice making machines often lack adequate interior packaging (e.g. side and coil protection), which leaves the freight vulnerable to dents, punctures and crushing. Shippers reported a range from three to 31 claims per year, with one stating it averages one to two claims per month. Value information indicates a range from $4.43 to $16.67 per pound, with an average value of $10.34 per pound. Item currently authorizes Packages 2163, 2370 and However, photos and reports received from carriers show that these types of packages which may or may not fully comply with the respective specifications are failing and resulting in damage to ice making machines. Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that the involved articles range in density from 1.08 to pcf, with an overall average density of 8.55 pcf. Per CCSB density guidelines, an average density of 8.55 pcf is generally associated with class 110, which calls for a minimum average density of 8 pcf. However, CCSB policies further state that when commodities exhibit a wide density range not accurately reflected by a single, overall average density, they may be assigned density-based classes. Moreover, in this instance, research has identified significant negative handling, stowability and liability characteristics, regardless of method of tender, and these characteristics must also be considered, in accordance with CCSB policies. These factors have been detailed in this analysis and include, but are not limited to, the need for additional care and attention to handle the freight, the difficulty or inability to stack top freight, and the risk of damage. Taking all these factors into consideration, this proposal would establish provisions based on density intervals of less than 6 Subject 2, Page 6 of National Motor Freight Traffic Association, Inc.

7 pcf, 6 but less than 10 pcf, and 10 pcf or greater 2. Due to the identified negative handling, stowability and liability issues, a one-class adjustment is proposed, as shown in the table below. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines Class Adjustment Based on Handling, Stowing and Liability Considerations Less than but less than or greater Additionally, CCSB packaging policy calls for establishing and maintaining packaging specifications as necessary to ensure that freight is adequately protected and can be handled and stowed in a manner that is reasonably safe and practicable so as to withstand the normal rigors of the less-than-truckload environment. Because these articles are susceptible to damage, and in view of information submitted by carriers, the CCSB s Packaging Consultant has determined that Packages 2163, 2370 and 2481 no longer provide a satisfactory level of protection for ice making machines in today s less-than-truckload environment. Thus, canceling Packages 2163, 2370 and 2481 and removing reference to them from item , as proposed, would be in keeping with CCSB packaging policies. Furthermore, as proposed, two new Notes would be established, which would be in keeping with CCSB policies. The first new Note would require the articles to be protected by packing forms or other packaging materials necessary to prevent damage, and the second new Note would require those articles that are tendered on lift truck skids or pallets to be securely fastened to and not overhang the edges of the lift truck skid or pallet deck. Precedent for this approach can be found in Docket , Subject 11 (January 2013), involving screen doors or window screens. The provisions established in that proposal were based on two density breaks at 6 and 10 pcf with a one-class adjustment from the CCSB s density guidelines to reflect the negative impact of handling, stowability and liability factors. That proposal was approved as docketed, and the provisions first appeared in Supplement 1 to NMF 100-AM, effective April 20, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 2 The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 2, Page 7 of 7