DOCKET OCTOBER 2018

Transcription

1 DOCKET OCTOBER 2018 A public meeting on National Motor Freight Classification provisions will be held on October 16, 2018 at: Hyatt Regency Savannah 2 West Bay Street Savannah, Georgia ISSUED: September 13, 2018

2 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET On Tuesday, October 16, 2018, the Commodity Classification Standards Board (CCSB) will conduct a public meeting to consider proposals for amending the National Motor Freight Classification (NMFC ). The meeting will be held at the Hyatt Regency Savannah, 2 West Bay Street, Savannah, Georgia 31401, commencing at 1:00 pm Eastern Time. Section I of this docket provides the CCSB analyses for proposed amendments that will be considered at the meeting. Each analysis includes the full text of the proposal, the CCSB contact and the identity of the proponent. Section II of this docket provides the CCSB analyses for two proposals from Docket on which disposition was deferred to the October 16, 2018 meeting. Each analysis includes the full text of the proposal, the CCSB contact and the identity of the proponent. Section III of this docket provides notice of classification changes made necessary by law, by order of a regulatory body, or for clarification, simplification or uniformity. The symbol indicates a proposed classification change. The symbol indicates that the commodities may be subject to federal regulations concerning the shipping of hazardous materials. The symbol indicates a registered trade name or registered trademark. The symbol indicates a trademark. Public Docket Files Supporting data and other relevant information pertaining to each proposal in Sections I and II herein are contained in a Public Docket File. The public files are available online without charge at They are organized by docket and subject numbers. Commodity Classification Standards Board ccsb@nmfta.org Chairman Joel L. Ringer Vice Chairman William F. Mascaro Member Allison L. Austin Member George M. Beck Member Daniel E. Horning Member Lisa K. O Donnell Member/Packaging Consultant Erin N. Topper Counsel John R. Bagileo Page i

3 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET The Commodity Classification Standards Board invites all interested persons to participate in the classification process. Anyone having an interest in a proposal listed in this docket may attend the meeting on October 16, 2018 and/or communicate that interest in writing by mail, or fax prior to the meeting. Such Interested Persons will be notified of the CCSB s disposition of the proposal. To become a Party of Record to a proposal herein, one must communicate an interest in writing by mail, or fax, and must submit pertinent information relating to the transportation characteristics of the product(s) involved, or relevant to packaging materials or methods in connection with proposed packaging amendments, and it must be received no later than 5:00 pm Eastern Time, October 4, Parties of record will be notified of the CCSB s disposition of the proposal and will be entitled to seek reconsideration should they disagree with that disposition. Written submissions received by 5:00 pm Eastern Time, October 4, 2018, will be included in the respective public docket file and posted on our website. The CCSB s decision on each proposal will be based on the information in the public docket file. Statements and other materials received by the CCSB after 5:00 pm Eastern Time, October 4, 2018, will not be part of the public docket file. Our address is: Commodity Classification Standards Board, 1001 North Fairfax Street, Suite 600, Alexandria, Virginia 22314, and our fax number is: Written statements may also be ed to the CCSB contact involved. To schedule an appearance at the meeting, or if you require further information, please get in touch with the CCSB contact. Anyone requesting assistance in accordance with the Americans with Disabilities Act will be accommodated. The CCSB s policies and procedures as well as other information on the CCSB and the National Motor Freight Traffic Association are available online at Amendments to the National Motor Freight Classification resulting from the proposals in this docket will be published in a supplement to the NMFC, unless reconsideration is granted in accordance with the CCSB s rules. The supplement is scheduled to be issued on November 29, 2018, with an effective date of December 29, Future CCSB Dockets Docket Docket Docket Closing Date November 29, 2018 April 11, 2019 Docket Issue Date January 10, 2019 May 9, 2019 Deadline for Written Submissions and to Become a Party of Record February 1, 2019 May 31, 2019 CCSB Meeting Date February 12, 2019 June 11, 2019 Dates are as currently scheduled and subject to change. For up-to-date information, go to Page ii

4 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET INDEX OF SUBJECTS (PROPOSALS) DESCRIPTION SUBJECT DESCRIPTION SUBJECT B Backs, chair, laminated paperboard or pulpboard Blocks, hat, wooden Boots... 1 Briquettes, sponge iron C Cabinets, bathroom medicine or toilet Chair Backs, laminated paperboard or pulpboard Compounds, floor sweeping or spill absorption Cups, baking or candy, paper D Duct, air distributing, ventilating or exhaust system, flexible... 6 F Fans, electric, NOI, or Exhaust or Ventilating Fans... 8 Feed, Feed Supplements, or Feeding Compounds or Preparations... 4 Filters, liquid or gas, cartridge or tank type Floor Sweeping Compounds Footwear... 1 G Garage Door Operators or Openers H Hat Blocks, wooden I Ice Making Machines... 2 Item (Rule) 110, Sec. 5, Definition of Shipment Item (Rule) 540, Secs. 1(a) and 2(c), Hazardous Materials... 5 Item (Rule) 680, Sec. 1(a) and Note 2, Maximum Allowable Dimensions of Lift Truck Skids, Pallets or Platforms for Potentially Unstable Commodities... 3 Item (Rule) 680, Sec. 5, Definition of Loose J Jacks or Jackscrews Japan Wax Substitute L Liners, baking, paper Loose Definition M Machines, ice making... 2 Mats, bathtub, shower stall, drainboard, sink or stove protector, plastic or rubber... 9 Molds, baking, paper O Oil Absorption Compounds Operators or Openers, garage door Oxidizers or Organic Peroxides... 7 Oxygen, recreational of Docket (See Section II herein.) P Package Package Package Package Package Package Packaging Definition of Loose Packaging Maximum Allowable Dimensions of Lift Truck Skids, Pallets or Platforms for Potentially Unstable Commodities... 3 Packaging Self-Supporting (Rigid) Fiberglass Reinforced Plastic (FRP) Sheet... 7 of Docket (See Section II herein.) Pellets, sponge iron Pet Food... 4 R Racks, spice Recreational Oxygen of Docket (See Section II herein.) Page iii

5 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET INDEX OF SUBJECTS (PROPOSALS) DESCRIPTION SUBJECT DESCRIPTION SUBJECT S Sheet, self-supporting (rigid) fiberglass reinforced plastic (FRP) Packaging... 7 of Docket (See Section II herein.) Shipment Definition Shoes or Slippers... 1 Spice Racks Spill Absorption Compounds Sponge Iron Briquettes or Pellets Substitute, Japan wax Swabs, Swab Sticks or Swab-type Applicators Page iv

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7 SUBJECT 1 Re: Footwear Item CCSB Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BOOT GROUP: subject to item Boots, NOI; Footwear, NOI, other than hosiery; Shoes, NOI; or Slippers; in boxes Proposed Classification Provisions Item Description Class BOOT GROUP: subject to item Boots, NOI; Footwear, NOI, other than hosiery; Shoes, NOI; or Slippers; in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 or greater Analysis Research Project 1307 This proposal is based on information developed through Research Project 1307, which was initiated in May of 2017 to investigate the transportation characteristics of footwear, as named in item History of Provisions Provisions for boots or shoes, as named in item 28160, were adopted from the rails and first appeared in LTL-1, effective April 1, 1936 at a rating equivalent to class 100. The current provisions of item were established as a result of action taken on Docket , Subject 2 (October 2009) and first appeared in Supplement 5 to NMF 100-AI, effective January 9, The provisions have remained unchanged to the present. Subject 1, Page 1 of 3

8 SUBJECT 1 About Footwear This proposal encompasses various articles of footwear, other than hosiery, including boots, shoes and slippers. Examples are shown below. Transportation Characteristics Density The information of record includes 63,873 density observations submitted by carriers and shippers, observed firsthand on CCSB dock surveys, and obtained from the CCSB s Density Study 1. The densities range from 0.18 to pcf, with an average of 5.67 pcf. When the data is evaluated based on a density break at 6 pcf, the resultant ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling and Stowability The involved articles are generally tendered in fiberboard boxes, which may be secured on lift truck skids or pallets. There have been no reports of unusual or significant handling or stowability problems. Liability Footwear is not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor likely to damage other freight. Responding carriers and shippers did not report any unusual or significant claims problems. Limited information on the value per pound of the involved articles indicates a range from $8.00 to $13.88 per pound, with an average of $11.46 per pound. Relationship to CCSB Policies and Guidelines CCSB policies call for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record for footwear indicates that these products have a density range from 0.18 to pcf, with an overall average density of 5.67 pcf, and no unusual or significant handling, stowability or liability characteristics. Per CCSB density guidelines, an average density of 5.67 pcf is generally associated with class 175, which calls for a minimum average density of 5 pcf. However, CCSB policies further state that when commodities exhibit a wide density range, density-based 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 1, Page 2 of 3

9 SUBJECT 1 classes may be established. As shown in the table below, the data can be divided into two density groupings of less than 6 pcf, and 6 pcf or greater, with classes reflective of the average density of each respective grouping. Density Group (pcf) Average Density (pcf) CCSB Minimum Average Density Guideline (pcf) Class Based on CCSB Density Guidelines Less than or greater It would be in keeping with CCSB policy and precedent to amend item to provide classes predicated on density, with a single density break at 6 pcf 2. Precedent for this approach can be found in Docket , Subject 5 (June 2018), involving hosiery, including pantyhose, socks or stockings. No significant handling, stowability or liability concerns were reported and, as such, density was determined to be the primary transportation characteristic. While the densities were distributed throughout the range of 0.50 to pcf, a single density break at 6 pcf was proposed to provide a more accurate representation of the identified density range. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AR, effective August 25, 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. Subject 1, Page 3 of 3

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11 SUBJECT 2 Re: Ice Making Machines Item CCSB Contact: Larissa A. Franklin Telephone (703) franklin@nmfta.org 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 Subject 2, Page 1 of 7

12 SUBJECT 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 7

13 SUBJECT 2 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 Subject 2, Page 3 of 7

14 SUBJECT 2 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 7

15 SUBJECT 2 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. Subject 2, Page 5 of 7

16 SUBJECT 2 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 7

17 SUBJECT 2 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. Subject 2, Page 7 of 7

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19 SUBJECT 3 Re: Item (Rule) 680, Sec. 1(a) and Note 2 CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 680, Packing or Packaging General, to read as follows: ITEM 680 PACKING OR PACKAGING GENERAL General Sec. 1. (a) The separate descriptions of articles provide the minimum, acceptable packaging requirements, see Note 1. Numbered packages or other packaging provisions (other than 'DOT Specification Number' packages, for which, see DOT's hazardous materials regulations) are authorized for use only when item descriptions contain reference thereto. The definitions of or specifications for packaging requirements are provided in: (1) Items 200 through 299, (2) numbered packages and (3) Note references. The minimum requirements notwithstanding, articles must be tendered for shipment in such a manner as to withstand the normal rigors of the less-than-truckload environment. Whether or not part of the specific requirements, protective packing forms or other packaging materials must be used where necessary to afford adequate protection against damage to the articles being shipped. Articles or articles and necessary interior packing forms must reasonably occupy the full cubic capacity of the outer shipping container, see Notes 2(a), 3 and 4. Articles unitized or secured on lift truck skids, pallets or platforms must reasonably occupy the full surface area of the lift truck skid, pallet or platform, see Note 2(b) and (c). Note 1 No Change. Note 2 (a) Reasonable Occupancy of Shipping Container. Unless otherwise provided, commodities in shipping containers (not containers within containers) shall be deemed to be in compliance when filled to not less than 65 percent of the capacity of such containers. When filled to less than 65 percent of capacity, the gross weight of the container and its contents will be subject to the class applicable to either the container or its contents, whichever is higher. Subject 3, Page 1 of 5

20 SUBJECT 3 Proposed Classification Provisions Concluded (b) Reasonable Occupancy of Lift Truck Skid, Pallet or Platform Deck. Unless otherwise provided, and except as permitted in paragraph (c), commodities unitized or secured on lift truck skids, pallets or platforms shall be deemed to be in compliance when occupying not less than 65 percent of the full surface area (deck) of the lift truck skid, pallet or platform. The surface area occupied shall be determined by multiplying the greatest straight-line dimensions of length and width of the commodity(ies). Banding, strapping or wrapping will not be considered in the determination of occupancy. When less than 65 percent of the surface area of the lift truck skid, pallet or platform is occupied, the gross weight of the lift truck skid, pallet or platform and the commodity(ies) unitized or secured thereon will be subject to the class applicable to either the lift truck skid, pallet or platform or the commodity(ies), whichever is higher. Any part of the commodity(ies) shipped that may overhang the lift truck skid, pallet or platform will not be used in determining occupancy of the surface area, but will be used in the computation of density. (See Item 110, Sec. 8-8(d).) (c) Maximum Allowable Dimensions of Lift Truck Skids, Pallets or Platforms for Potentially Unstable Commodities. For the purpose of this rule, commodities having an overall height 1.5 times or more their shortest base dimension shall be considered potentially unstable. For such commodities, the lift truck skid, pallet or platform may be of sufficient size to provide adequate stability. The maximum allowable dimensions of the lift truck skid, pallet or platform are determined using the following formulas. The Maximum Allowable Length is the larger result of the following calculations: Maximum Allowable Length (in) = Commodity s(ies ) Height (in) x 0.67 OR Maximum Allowable Length (in) = Commodity s(ies ) Length (in) + 12 (in) The Maximum Allowable Width is the larger result of the following calculations: Maximum Allowable Width (in) = Commodity s(ies ) Height (in) x 0.67 OR Maximum Allowable Width (in) = Commodity s(ies ) Width (in) + 12 (in) If the lift truck skid, pallet or platform exceeds the maximum allowable length or width, as calculated above, the gross weight of the handling unit will be subject to the class applicable to either the lift truck skid, pallet or platform or the commodity(ies) being shipped, whichever is higher. Notes 3-4 No Change. Sec. 1. (b) No Change. Secs No Change. Subject 3, Page 2 of 5

21 SUBJECT 3 Analysis This proposal seeks to address interpretive issues with the 65% rule published in Item (Rule) 680, Note 2 to address potentially unstable commodities. Freight offered to carriers in well-constructed loads on appropriately sized lift truck skids, pallets or platforms is generally easier and safer for carrier personnel to handle and stow, and consumes suitable vehicle space. Freight tendered securely fastened on lift truck skids, pallets or platforms offered on improperly sized lift truck skids, pallets or platforms may consume more space than needed or may present unsafe handling and stowing conditions. Recent interpretations have revolved around the necessity of larger lift truck skids, pallets or platforms in order to stabilize the handling unit due to the configuration of the articles shipped. Potentially unstable commodities have an overall height that is 1.5 times or more than their shortest base dimension. The use of a larger lift truck skid, pallet or platform helps ensure stability and safety, and helps to mitigate the chance of damage to the commodity and other freight with which shipped. Unstable handling units, such as the flat glass in the photo on the right, can tip and fall when being handled and when being transported in a vehicle, resulting in crushing of adjacent freight, damage to the freight itself and potential injury to carrier personnel. They may also require securement while being stowed at carrier facilities, as well as when loaded in the vehicle, to ensure they do not fall over. The diagram below illustrates how the various widths of the lift truck skid, pallet or platform are evaluated. The area in brown indicates that the handling unit is potentially unstable and may be top heavy; green provides the necessary dimensions for a stable handling unit; red indicates an excessively large lift truck skid, pallet or platform. Subject 3, Page 3 of 5

22 SUBJECT 3 Currently, when the commodity does not occupy 65% or more of the lift truck skid, pallet or platform deck, per Item 680, Note 2(b), the handling unit is subject to the class applicable to either the lift truck skid, pallet or platform or the commodity(ies) being shipped, whichever is higher. The application of this Note can discourage the use of appropriately sized lift truck skids, pallets or platforms to stabilize an otherwise unstable commodity. This proposal would establish a method of mathematically calculating the maximum size of the lift truck skid, pallet or platform that is necessary and reasonable to create a stable handling unit. For example, assuming a commodity is 40 inches long, 30 inches wide and 80 inches tall, the height to shortest dimension ratio is is greater than 1.5, therefore, the commodity is potentially unstable. The maximum allowable lift truck skid, pallet or platform length and width would be calculated as follows. Maximum Allowable Length: Maximum Allowable Length = 80 in x 0.67 = 53.6 in OR Maximum Allowable Length = 40 in + 12 in = 52 in Maximum Allowable Width: Maximum Allowable Width = 80 in x 0.67 = 53.6 in OR Maximum Allowable Width = 30 in + 12 in = 42 in The larger result of the respective calculations yields a maximum allowable lift truck skid, pallet or platform of 53.6 x 53.6 inches. The following decision tree provides guidance for applying Note 2(b) and (c). 1 The height is 2.67 times larger than the shortest base dimension, which is calculated by dividing 80 inches by 30 inches. Subject 3, Page 4 of 5

23 SUBJECT 3 Relationship to CCSB Policies and Guidelines CCSB packaging policies state the CCSB is to establish and maintain packaging rules and 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. This proposal would establish a mathematical determination of the maximum allowable dimensions (length and width) of lift truck skids, pallets or platforms for stabilizing potentially unstable commodities, and provides that lift truck skids, pallets or platforms found to exceed those dimensions are to be classified as either the lift truck skid, pallet or platform or the commodity(ies), whichever results in the higher class. Additional changes are proposed for clarification and uniformity. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies. Subject 3, Page 5 of 5

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25 SUBJECT 4 Re: Feed, Feed Supplements, or Condimental or Medicinal Feeding Compounds or Preparations, animal, fish or poultry, not frozen Items 67060, and CCSB Contact: Allison L. Austin Telephone (703) austin@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FEED GROUP: subject to item Feed, animal, fish or poultry, prepared, NOI, not frozen; in bags, see Note, item 67061, boxes, drums or Packages 1000, 1271, 1500, 2257, 2330, 2334, 2382 or 2421; or in fused or pressed blocks weighing each 33 pounds or over, in packages NOTE Bags need not meet the provisions of Item 200 when net weight does not exceed 60 pounds Feed Supplements; or Condimental or Medicinal Feeding Compounds or Preparations; animal, fish or poultry, not frozen; released to a value not exceeding 50 cents per pound, see Note, item 67072, in inner containers in boxes or drums or in bulk in bags, boxes, drums, pails or Package NOTE The released value must be entered on the shipping order and bill of lading in the following manner: 'The agreed or declared value of the property is hereby specifically stated by the shipper to be not exceeding 50 cents per pound.' When the foregoing statements are properly executed, the rates subject hereto will take precedence over all other rates not subject to released value, provided the released rates result in lower freight charges. If lower freight charges do not result, the release will be deemed not to have been executed and the rates subject hereto will have no application. If the shipper fails or declines to execute the above statements, or designates a value exceeding 50 cents per pound, shipments will not be accepted for transportation at the rates subject hereto. Rates based on other classes in this Classification will apply in such a case. (Classes herein based on released value have been authorized by the Interstate Commerce Commission in Released Rates Order No. MC- 827 of April 7, 1972, as amended May 28, 1980.) Feed Supplements; or Condimental or Medicinal Feeding Compounds or Preparations; animal, fish or poultry, not frozen, not released as to value, in containers in boxes or drums, or in bulk in bags, boxes, drums, pails or Packages 2440 or Subject 4, Page 1 of 6

26 SUBJECT 4 Present Classification Provisions Concluded Package 2334 Bags having 5 and 10 pounds net weight, not complying as shipping containers, may be bundled by unitizing bags totalling not more than 42 pounds net weight compressed within a corrugated fiberboard sleeve testing 275 pounds. Sleeve and contained bags must then be encircled with plastic heat shrinkable film of not less than 3 mils in thickness with film openings only on faces of corrugated sleeve. Proposed Classification Provisions Item Description Class FEED GROUP: subject to item A-NEW Feed or Feed Supplements, animal, fish or poultry, other than frozen and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items B-NEW and C-NEW, viz.: Feed, prepared, NOI; Feed Supplements; Feeding Compounds or Preparations, condimental or medicinal; Pet Food, prepared, NOI; In bags, boxes, drums, pails or Packages 1000, 1271, 1500, 2257, 2330, 2421, 2440 or 2521, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 15 but less than Sub 3 30 or greater B-NEW NOTE Does not apply on materials regulated by the U.S. Department of Transportation as hazardous and required to bear a Hazard Class or Hazard Division label. For classes applicable to such hazardous materials, see provisions elsewhere in this Classification. C-NEW NOTE Does not apply on edible pet treats in various forms or shapes. For applicable provisions, see item Feed, animal, fish or poultry, prepared, NOI, not frozen, etc.... Cancel; see item A-NEW NOTE Cancel; no further application Feed Supplements; or Condimental or Medicinal Feeding Compounds or Preparations; animal, fish or poultry, not frozen; released to a value not exceeding 50 cents per pound, etc.... Cancel; see item A-NEW and provisions otherwise applicable NOTE Cancel; no further application. Subject 4, Page 2 of 6

27 SUBJECT 4 Proposed Classification Provisions Concluded Item Description Class FEED GROUP: subject to item Feed Supplements; or Condimental or Medicinal Feeding Compounds or Preparations; animal, fish or poultry, not frozen, not released as to value, etc.... Cancel; see item A-NEW and provisions otherwise applicable Package 2334 Cancel; no further application. Analysis Research Project 1325 This proposal is based on the information developed through Research Project 1325, which was initiated in November 2017 to investigate the transportation characteristics of animal, fish or poultry feed, feed supplements, or condimental or medicinal feeding compounds or preparations, as embraced by items 67060, and Hereinafter, the involved products will be referred to as feed or feed supplements. History of Provisions The basic provisions of item were adopted from the rails in The current provisions were established as a result of action taken on Docket 908, Subject 9 (December 1990) and first appeared in Supplement 8 to NMF 100-Q, effective April 13, The provisions have remained substantially unchanged to the present. The released-value provisions of item 67070, including Note, item 67072, and the fullvalue provisions of item 67075, were established as a result of action taken on Docket 704, Subject 9 (July 1970) and first appeared in Supplement 4 to NMF 100, effective March 2, The provisions have remained substantially unchanged to the present. About Feed or Feed Supplements This proposal involves an array of products that are generally designed to provide nutritive value and/or affect the health, performance and well-being of animals, fish or poultry. It includes articles intended for consumption by pets commonly referred to as pet food that are not more specifically named elsewhere in the Classification. For example, the proposal does not encompass edible pet treats, which are embraced by item While some products are regulated as hazardous materials by the U.S. Department of Transportation (DOT), the information of record has been limited to feed or feed supplements not regulated by the DOT. Examples of some of the involved commodities are shown on the following page. Subject 4, Page 3 of 6

28 SUBJECT 4 Transportation Characteristics Density Information of record for feed or feed supplements includes 66,126 density observations submitted by shippers and carriers, collected during CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 1.38 to pcf, with an average density of pcf. When the data is evaluated based on density breaks at 15 and 30 pcf, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater 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 4, Page 4 of 6

29 SUBJECT 4 Handling and Stowability Feed or feed supplements are tendered for shipment in a variety of packages, including bags, boxes, drums or pails, which are typically secured on lift truck skids or pallets. As with food for humans, care must be taken to avoid stowing the involved products with hazardous materials or other freight that may pose a contamination risk. However, there have been no reports of unusual or significant handling or stowability problems. Liability Feed or feed supplements are not generally perishable, hazardous in nature, unusually susceptible to theft, and would not appear likely to damage other freight. The involved products may be damaged by freight with which stowed or by the elements. As with other food, these products may require extra care or attention to avoid contamination. One carrier reports a year-to-date claims ratio of 0.53% for item and zero claims for items and A second carrier reports 146 claims for damage and three claims for loss for feed supplements over a two-year period. The carrier indicates these damage claims are often due to issues with products tendered in bags on lift truck skids or pallets not being adequately protected by additional packaging. A third carrier notes similar issues with bagged freight. Item (Rule) 680, Sec. 7(b)(2) stipulates, in part, that articles in bags unitized on lift truck skids, pallets or platforms must be protected by fiberboard at least 20 inches up from the lift truck skid, pallet or platform deck with either a fiberboard tray or a fiberboard tray and sleeve combined. If shippers were to comply with these packaging requirements, these damage issues could be mitigated. Additionally, responding shippers report zero to 20 claims annually. The value per pound ranges from $0.35 to $20.12, with an average value of $7.89 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for combining item descriptions embracing related commodities, adding commonly used terminology, and structuring item descriptions so as to foster clarification and simplification. Therefore, it would be in keeping with CCSB policy to cancel items 67060, and with reference to a new item for feed or feed supplements. As proposed, the new item would provide a viz. listing to name articles embraced by the item. It would also restrict the item s application to non-hazardous materials. A new Note would be added to direct the Classification user to other applicable items in the NMFC for hazardous products. Additionally, a new Note would be established to clarify that the provisions do not apply on edible pet treats in various forms or shapes, and to direct the Classification user to item for applicable provisions. Subject 4, Page 5 of 6

30 SUBJECT 4 CCSB policy also calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for feed or feed supplements shows that these products have a density range from 1.38 to pcf, with an average density of pcf. While there are some handling, stowability and liability concerns inherent with shipping feed or feed supplements, they do not appear to significantly impact the transportability of these products. Under CCSB guidelines, an average density of pcf is generally associated with class 70, which calls for a minimum average density of 15 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policy states that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 15 and 30 pcf, the following average densities and classes emerge. Density Group (pcf) Average Density (pcf) CCSB Minimum Average Density Guideline (pcf) Class Based on CCSB Density Guidelines Less than but less than or greater It would be in keeping with CCSB policy and precedent to establish classes predicated on two density breaks at 15 and 30 pcf for the involved products 2. Precedent for this approach can be found in Docket , Subject 4 (January 2016), involving foil, foil wrappers or foil scrap, as named in item Density was determined to be the primary transportation characteristic since there were no significant handling, stowability or liability concerns reported. Two density breaks at 15 and 30 pcf were proposed to provide a more accurate representation of the identified density range of 1.39 to pcf. That proposal was approved as docketed, and the provisions first appeared in Supplement 1 to NMF 100-AP, effective April 16, As proposed, the provisions would no longer make distinctions based on released value. Therefore, Note, item would be canceled as having no further application. Furthermore, CCSB packaging policy calls for packaging specifications that ensure the 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. As such, several packaging changes would be made, including the cancelations of Note, item and Package 2334 as having no further application, and the removal of reference to Package 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. Subject 4, Page 6 of 6

31 SUBJECT 5 Re: Item (Rule) 540 Hazardous Materials CCSB Contact: Lisa K. O Donnell Telephone (703) odonnell@nmfta.org Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 540, Hazardous Materials, to read as follows: ITEM 540 HAZARDOUS MATERIALS (see Notes A and C) Sec. 1. Compliance with Department of Transportation (DOT) Descriptions and Packaging Requirements: Sec. 1(a). Articles subject to the DOT's hazardous materials regulations must be described on bills of lading and shipping orders as shown in those regulations. Abbreviations must not be used, except as authorized in 49 CFR When the DOT's hazardous materials regulations description differs from the Classification description, the Classification description must also be shown on bills of lading and shipping orders. Sec. 1(b). No Change. Secs. 2-2(b). No Change. Sec. 2(c). When carriers are required by federal, state or local regulations or statutes to pay fees to acquire permits to transport hazardous materials, wastes or substances, or radioactive articles or materials, the cost of acquiring such permits, including administrative or service charges where provided in carrier tariffs, will be paid by the party remitting the linehaul charges. Upon request, evidence of payment of the costs of acquiring permits shall be furnished. Secs. 2(d)-5. No Change. Notes A-E No Change. Analysis and Relationship to CCSB Policies and Guidelines Sec. 1(a) of Item (Rule) 540 states that abbreviations must not be used on bills of lading and shipping orders when describing materials regulated by the U.S. Department of Transportation (DOT) as a hazardous material. However, the hazardous materials regulations in 49 CFR , which specifies the description of hazardous material on shipping papers, authorizes certain abbreviations, as long as the abbreviations are commonly accepted and recognizable. Specifically, 49 CFR (a)(7) allows the use of abbreviations to indicate packaging types (e.g., cyl. for cylinder ) and 49 CFR (c)(1) allows the use of abbreviations to express units of measurement and types of packaging. Subject 5, Page 1 of 2

32 SUBJECT 5 Sec. 2(c) of Item 540 specifies that the party remitting the line-haul charges is responsible for the costs incurred when acquiring special permits to transport hazardous materials, wastes or substances, or radioactive articles or materials; however, the wording may lead to interpretation questions as it alludes to special permits that are required by the federal government. Special permits are issued free-of-charge by the DOT and are, by definition, exceptions to federal hazardous materials regulations, not requirements. Accordingly, this proposal would amend Item 540 to allow abbreviations authorized in 49 CFR to be used on bills of lading and shipping orders. It would also amend Sec. 2(c) of Item 540 in the interest of clarification. This proposal, as docketed, is in keeping with CCSB policies. Subject 5, Page 2 of 2

33 SUBJECT 6 Re: Duct, air distributing, ventilating or exhaust system, flexible Item CCSB Contact: Kyle R. Smith Telephone (703) kyle.smith@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item Duct, air distributing, ventilating or exhaust system, flexible, see Note, item 51036, in packages, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 2 but less than Sub 3 3 but less than Sub 4 4 but less than Sub 5 6 or greater NOTE The term flexible is descriptive of duct which may withstand a bend of 180 over a mandrel having a diameter equal to the inside diameter of the duct and return to original shape without deterioration of the wall structure. Proposed Classification Provisions Item Description Class CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item Duct, air distributing, ventilating or exhaust system, flexible, see Note, item 51036, in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 4 but less than Sub 3 6 or greater NOTE No Change. Analysis Research Project 1313 Research Project 1313 was initiated in August of 2017 to review the transportation characteristics of flexible duct, as named in item Subject 6, Page 1 of 4

34 SUBJECT 6 History of Provisions As a result of action taken on Docket 765, Subject 56 (July 1976), separate items for flexible duct were consolidated, and the current description of what is now item and language of Note, item were established, and first appeared in Supplement 16 to NMF 100-C, effective March 19, The provisions have remained substantially unchanged to the present. About Flexible Duct Flexible duct is used to distribute air in a heating, ventilating or air conditioning system, or to collect air in an exhaust system. Material composition includes a variety of materials and can consist of metal, plastic, fabric and insulation. Transportation Characteristics Density The information of record for products moving under item includes 7,905 density observations submitted by shippers and carriers, collected during CCSB carrier dock surveys and a shipper dock survey, and obtained from the CCSB s Density Study 1. The densities range from 0.34 to pcf, with an overall average of 4.87 pcf. When the data is evaluated on the basis of the three proposed density groupings, as shown in the table on the following page, the resultant ranges and averages emerge. 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 6, Page 2 of 4

35 SUBJECT 6 Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling and Stowability The information of record indicates that flexible duct is tendered in boxes or bags secured to lift truck skids or pallets. Due to the inherent nature of the commodity, heavy freight should not be loaded on top of shipments of flexible duct. However, there have been no reports of unusual or significant handling or stowing issues. Liability Flexible duct is not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor does it appear likely to damage other freight. No carriers have reported claims, and shippers reported between zero and two claims per year. Reports of value per pound range from $3.41 to $34.00, with an average of $12.78 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for flexible duct shows that these products have a density range of 0.34 to pcf, with an overall average of 4.87 pcf, and no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of 4.87 pcf is generally associated with class 200, which calls for a minimum average density of 4 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 4 and 6 pcf, the following average densities and classes emerge. Density Group (pcf) Average Density CCSB Minimum Average Class Based on CCSB (pcf) Density Guideline (pcf) Density Guidelines Less than but less than or greater It would be in keeping with CCSB policy and precedent to amend the density-based provisions of item 51035, as proposed. The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. However, pursuant to CCSB policy and precedent, other density-based classifications, such as item 51035, should not include reference to Item 171. Accordingly, this proposal would remove the reference to Item 171 from item Subject 6, Page 3 of 4

36 SUBJECT 6 A precedent similar to this approach can be found in Docket , Subject 9 (February 2018), involving borax. No significant handling, stowing or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. Borax exhibited a range of densities from 2.29 to pcf the distribution of which was no longer accurately represented by full-scale density provisions, and, as such, density breaks were proposed at 22.5 and 30 pcf to provide a more accurate representation of the density observations. The proposed density-based provisions included reference to Item 170 but not Item 171. That proposal was approved as docketed, and the changes first appeared in Supplement 1 to NMF 100-AR, effective April 28, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 6, Page 4 of 4

37 SUBJECT 7 Re: Oxidizers and Organic Peroxides Hazard Divisions 5.1 and 5.2 CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class CHEMICALS GROUP: see Notes, items and NOTE Not Involved NOTE 1. Materials regulated by the U.S. Department of Transportation that are required to bear any of the Hazard Class 6 or Hazard Division 6.1 labels listed below are subject to the provisions of item 45615, regardless of the DOT-designated Hazard Class or Hazard Division. (a) 'INHALATION HAZARD' (b) 'POISON' (c) 'TOXIC' (d) 'PG III' 2. Not Involved. Ammonium: subject to item Nitrate, in bags, boxes or drums Perchlorate, offered for transportation as a Hazard Class 5, Division 5.1, see Notes, items and 43052: Sub 1 In inner containers in boxes Sub 2 In bulk in boxes or drums NOTE Applies on materials regulated by the U.S. Department of Transportation as a Hazard Class 5, Division 5.1, Oxidizer, as defined in 49 CFR and required to bear a notice to that effect on bills of lading and packaging NOTE For provisions applicable to ammonium perchlorate offered for transportation as a Hazard Class 1, Division 1.1, see sub 1 of item 64300, naming 'Explosives, NOI.' Persulfate, in bags, boxes or drums Sulfate Nitrate (Leunsaltpeter): Sub 1 In inner containers in boxes Sub 2 In bulk in bags, boxes or drums Benzoyl Peroxide, in boxes or drums: Sub 1 Dry, or wet with less than 30 percent of water Sub 2 Granules, crystals or powders, wet with not less than 30 percent of water Calcium: subject to item Nitrate: Sub 1 In double bags, or in bulk in drums Sub 2 In inner containers in boxes Subject 7, Page 1 of 9

38 SUBJECT 7 Present Classification Provisions Concluded Item Description Class CHEMICALS GROUP: subject to item Guanidine Nitrate, in bags, boxes or drums Hydrogen Dioxide or Hydrogen Peroxide. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes Sub 3 In Package 200 or in glass carboys Potassium (Potash): subject to item Chlorate: Sub 1 In bulk in boxes or drums Sub 2 In inner containers in boxes or drums Nitrate (Saltpetre): Sub 1 In inner containers in boxes or drums Sub 2 In cloth or five-ply paper bags or in bulk in boxes or drums Perchlorate. See item for class dependent upon released value: Sub 1 In bulk in bags, boxes or drums Sub 2 In inner containers in boxes or drums Permanganate. See item for class dependent upon released value: Sub 1 In bulk in boxes or drums Sub 2 In inner containers in boxes or drums Persulfate, in bags, boxes or drums Sodium (Soda): subject to item Chlorate. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes or drums Nitrate (Chili Saltpetre). See item for class dependent upon released value: Sub 1 In inner containers in boxes or drums Sub 2 In cloth or five-ply paper bags or in bulk in boxes or drums Permanganate. See item for class dependent upon released value: Sub 1 In inner containers in boxes or drums Sub 2 In bulk in boxes or drums Peroxide, in boxes or drums Strontium Nitrate, in bags, boxes or drums Subject 7, Page 2 of 9

39 SUBJECT 7 Proposed Classification Provisions Item Description Class CHEMICALS GROUP: see Notes, items and NOTE No Change NOTE No Change. Ammonium: subject to item Nitrate, etc... Cancel; see item C-NEW Perchlorate, offered for transportation as a Hazard Class 5, Division 5.1, etc... Cancel; see item C-NEW NOTE Cancel; see item D-NEW NOTE Cancel; no further application Persulfate, etc... Cancel; see item C-NEW Sulfate Nitrate (Leunsaltpeter), etc... Cancel; see item C-NEW Benzoyl Peroxide, etc... Cancel; see item A-NEW Calcium: subject to item Nitrate, etc... Cancel; see item C-NEW Guanidine Nitrate, etc... Cancel; see item C-NEW Hydrogen Dioxide or Hydrogen Peroxide, etc... Cancel; see item C-NEW A-NEW Organic Peroxides, NOI, other than toxic, see Notes, items and B-NEW, in bags, boxes, drums or intermediate bulk containers (IBCs) B-NEW NOTE Applies on materials regulated by the U.S. Department of Transportation as a Hazard Class 5, Division 5.2, Organic Peroxide, as defined in 49 CFR and required to bear a notice to that effect on bills of lading and packaging. C-NEW Oxidizers, NOI, other than toxic, see Notes, items and D-NEW, in bags, boxes, drums or intermediate bulk containers (IBCs): Sub 1 In Packing Group I Sub 2 In Packing Group II Sub 3 In Packing Group III D-NEW NOTE Applies on materials regulated by the U.S. Department of Transportation as a Hazard Class 5, Division 5.1, Oxidizer, as defined in 49 CFR and required to bear a notice to that effect on bills of lading and packaging. Subject 7, Page 3 of 9

40 SUBJECT 7 Proposed Classification Provisions Concluded Item Description Class CHEMICALS GROUP: subject to item Potassium (Potash): subject to item Chlorate, etc... Cancel; see item C-NEW Nitrate (Saltpetre), etc... Cancel; see item C-NEW Perchlorate, etc... Cancel; see item C-NEW Permanganate, etc... Cancel; see item C-NEW Persulfate, etc... Cancel; see item C-NEW Sodium (Soda): subject to item Chlorate, etc... Cancel; see item C-NEW Nitrate (Chili Saltpetre), etc... Cancel; see item C-NEW Permanganate, etc... Cancel; see item C-NEW Peroxide, etc... Cancel; see item C-NEW Strontium Nitrate, etc... Cancel; see item C-NEW Analysis Research Project 1281 This proposal is based on information developed through Research Project 1281, which was initiated in June 2016 to review the transportation characteristics of materials regulated by the U.S. Department of Transportation (DOT) as Oxidizers and Organic Peroxides, Hazard Class 5, Hazard Divisions 5.1 and 5.2, respectively. Definitions, Regulations and Provisions An oxidizer is defined as a material that may, generally by yielding oxygen, cause or enhance the combustion of other materials 1. Oxidizers may be solid or liquid, and may be assigned Packing Group I, II or III depending on the degree of hazard. As shown in the present classification provisions herein, 17 NMFC item numbers were identified as applying on chemicals regulated as oxidizers CFR Subject 7, Page 4 of 9

41 SUBJECT 7 An organic peroxide is defined as any organic compound containing oxygen (O) in the bivalent -O-O- structure and which may be considered a derivative of hydrogen peroxide, where one or more of the hydrogen atoms have been replaced by organic radicals Division 5.2 organic peroxides are assigned to a generic system which consists of seven types. An organic peroxide identified by technical name in the Organic Peroxides Table in 49 CFR is assigned to a generic type in accordance with that table 2. The DOT requires the offeror to determine the hazard class of a hazardous material before the material is offered for transportation (see 49 CFR 171.1(b)(1)). When a material meets the definition of more than one hazard class or division as defined in 49 CFR part 173, the material must be classed according to the highest applicable hazard class. Hazard Classes 3 and 8 and Divisions 4.1, 4.2, 4.3, 5.1 and 6.1 are ranked in the precedence of hazard table shown in 49 CFR 173.2a(b). Because of the unique properties of materials in Hazard Division 5.2, 49 CFR 173.2a(c)(2) requires that a Division 5.2 material that meets the definition of any other hazard class or division as defined in 49 CFR part 173 shall be classed as Division 5.2. Organic peroxides may be solid or liquid. Benzoyl Peroxide, currently named in item 43480, is regulated as an organic peroxide. Transportation Characteristics Density The information of record includes 1,829 density observations submitted by a carrier, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 3. The densities range from 0.92 to pcf, with an overall average density of pcf. Handling Due to the hazardous nature of these materials, extra care and attention is necessary. Training carrier employees in handling hazardous materials and then supervising them to ensure compliance with DOT regulations takes additional time, more paperwork and extra personnel than that required when transporting nonhazardous freight. Personnel who must be trained in the intricacies of handling hazardous materials include: dispatchers, drivers (pickup, line-haul and delivery), driver supervisors, billing clerks, billing supervisors, terminal managers, freight handlers, dock foremen, maintenance personnel, safety and claims personnel, and even sales personnel CFR Exceptions to the definition for Class 5, Division 5.2 materials are provided in 49 CFR (a)(1) though (4). 3 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 7, Page 5 of 9

42 SUBJECT 7 The carrier s driver must check the accuracy of the information provided on the bill of lading and confirm that the shipper s compliance certification statement is included. Further, the driver must accurately count the number of pieces tendered, verify the inclusion of an emergency contact telephone number and verify the application of the proper hazard labels 4. It is also imperative that the driver be aware of the type of freight already in the vehicle to ensure the carrier complies with coloading prohibitions and segregation requirements. The driver must also be aware of the threshold quantities of hazardous materials that will trigger the need to display the appropriate warning placards on the vehicle. If placards are required, the driver must ensure that they are properly displayed on the vehicle (visible from the front, rear and both sides). The driver must also place the shipping documents for all hazardous materials on top of all documents for nonhazardous freight, or distinctively tab each hazardous materials shipping paper, and the hazardous materials documents must be kept within the driver s reach at all times. Considering the thousands of hazardous materials handled daily by for-hire carriers and the inescapable fact that leaks, spills, fires and accidents occur, emergency response information must be included in a shipping paper or with a shipping paper, in a manner that cross-references the description of the hazardous material on the shipping paper with the emergency response information contained in a separate document (see 49 CFR part 172, subpart G). In addition to these regulatory requirements, virtually every carrier has its own rules that detail the actions to be taken by drivers in the event of problems involving hazardous materials. Carrier billing personnel must be trained to recognize hazardous materials shipments and to accurately transfer all information on these materials from the bill of lading to the freight bill (a copy of which is used to move the freight through the carrier s system to its destination). Additionally, many carriers require that freight bills pertaining to hazardous materials be flagged as a means to ensure that freight handlers and drivers are aware of the dangers presented by the material. Terminal managers, dock foremen and freight handlers must all be trained to be familiar with the care and attention required in the handling of hazardous materials, including the coloading prohibitions and segregation of freight bearing different DOT-required hazard designation labels. Further, complying with the involved handling regulations requires at least one dedicated space on carrier docks for hazardous materials. Most general freight does not require a separate space on the carriers docks CFR , , , , , , Subject 7, Page 6 of 9

43 SUBJECT 7 Stowability Under DOT regulations, coloading prohibitions and segregation requirements apply on oxidizers and organic peroxides, as per the table below 5. These restrictions can limit where in the vehicle and with what freight the carrier can stow the shipments and can result in less than full utilization of vehicle capacity and/or necessitate the dispatch of more than one vehicle. Material and Hazard Division Notes gas zone A 2.3 gas Zone B liquids PG I zone A 8 liquids only Oxidizers (5.1) A 6 X X X X O O X O Organic peroxides (5.2) X X X X O X O X=Coloading Prohibition O=Segregation Requirement Liability Oxidizers and organic peroxides are hazardous in nature, may damage other freight and carrier equipment, and may pose a risk of injury to carrier personnel. According to the DOT s Office of Hazardous Materials Safety s Incident Reports Database, from January 2, 2015 through January 17, 2018, there were 2,164 incidents involving oxidizers transported by highway. The cost of damages for 310 of those incidents totaled $1,619,692, averaging approximately $5,200 per incident. In that same time period, there were 601 incidents involving organic peroxides. The cost of damages for 124 of those incidents totaled $675,086, averaging approximately $5,400 per incident. Relationship to CCSB Policies and Guidelines CCSB policies state that unusual or significant handling, stowability or liability characteristics may be contributing factors in the assignment of classes. As indicated, handling and stowing oxidizers and organic peroxides require extra care and attention due to the hazards involved and the applicable regulations. Additionally, the liability assumed by the carrier when transporting oxidizers and organic peroxides is greater than that typically assumed when transporting most general freight. Per the precedence of hazards from the DOT regulations, and found in Sec. 3(c) of NMFC Item (Rule) 540, because of their unique properties, materials in Division 5.2 that meet the definition of any other hazard class or division are classed as Division 5.2. Also, as shown in the Precedence of Hazard Table, as excerpted on the following page, Division 5.1 materials may have a higher degree of hazard than other types of hazardous materials CFR CFR (e)(5): The note A in the second column of the table means that, notwithstanding the requirements of the letter X, ammonium nitrate (UN1942) and ammonium nitrate fertilizer may be loaded or stored with Division 1.1 (explosive) or Division 1.5 materials, unless otherwise prohibited by (c). Subject 7, Page 7 of 9

44 SUBJECT 7 5.1, I( 1 ) 5.1, II( 1 ) Precedence of Hazard Table 7 [Hazard class or division and packing group] 5.1, III( 1 ) 6.1, I dermal 6.1, I oral 6.1 II 6.1 III 8, I liquid 8, I solid 8, II liquid 8, II solid 8, III liquid 4.1 II ( 2 ) ( 3 ) 8 ( 3 ) 4.1 ( 3 ) III ( 2 ) ( 3 ) 8 ( 3 ) 8 ( 3 ) II III I II III I ( 1 ) II ( 1 ) III ( 1 ) ( 1 ) See 49 CFR ( 2 ) Materials of Division 4.1 other than self-reactive substances and solid desensitized explosives, and materials of Class 3 other than liquid desensitized explosives. ( 3 ) Denotes an impossible combination. 8, III solid When establishing provisions for other hazardous materials, precedent has been to assign classes higher than those called for under the density guidelines, reflective of the respective hazards involved. In this instance, using the DOT s precedence of hazard, the degree of hazard of the involved Hazard Class 5 materials was compared to that of Poisonous or Toxic Materials, Hazard Class 6, Division 6.1, as named in item 45615, Corrosive Materials, Hazard Class 8, as named in item 44155, and Hazard Class 4, Divisions 4.1, 4.2 and 4.3 materials, as named in item 44515, to determine the relative degree of hazard. Based on that comparison, it would be in keeping with CCSB policies and precedent to establish a new item applying on Organic Peroxides, Hazard Division 5.2, under the Chemicals Group, at class 200, reflective of the relative degree of hazard. It would also be in keeping with CCSB policies and precedent to establish a new item applying on Oxidizers, Hazard Division 5.1, with classes reflective of the relative hazards, determined by the packing group of the material. Furthermore, in keeping with CCSB clarification policies and precedent, two new Notes would be established. One Note would be referenced by the new item for organic peroxides stating that the item applies on Organic Peroxides, Hazard Division 5.2, as defined by 49 CFR The second new Note would be referenced by the new item for oxidizers stating that the item applies on Oxidizers, Hazard Division 5.1, as defined by 49 CFR The NMFC currently contains 17 individual items that have been identified as applying on Division 5.1 materials, and one item that has been identified as applying on Division 5.2 materials. CCSB policies state that items embracing related commodities should be combined. It would be in keeping with CCSB policies to cancel the provisions of items 43020, 43050, 43055, 43100, 43790, 44580, 44640, 45740, 45820, 45830, 45840, 45845, 46250, 46410, 46490, and with reference to the new item for oxidizers, and the provisions of item with reference to the new item for organic peroxides. 7 Item (Rule) 540, Sec. 3(b) Subject 7, Page 8 of 9

45 SUBJECT 7 Note, item would be canceled with reference to the new Note for oxidizers. Note, item would be canceled as having no further application. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 7, Page 9 of 9

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47 SUBJECT 8 Re: Fans, NOI, including Exhaust or Ventilating Fans CCSB Contact: Keith L. Charles, Jr. Telephone (703) charles@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item Fans, exhaust or ventilating, with or without heating elements or lighting fixtures, see Notes, items and 61904, in boxes, crates or Packages 2044, 2046 or NOTE Also applies on installation equipment other than exterior shroud or cone-type roof or sidewall ventilators, and not in excess of 20 percent of the weight upon which charges are assessed NOTE Applies on fans designed for: (1) expelling from an area, air, dust, gas, odors, smoke or other contaminants, or (2) introducing into an area, air from an outside source Fans, NOI, see Notes, items and 61924, in boxes or crates NOTE Fan columns may be shipped in fiber tubes, walls not less than inch thick, ends securely plugged with wooden plugs NOTE Also applies on fans which when temporarily placed in openings such as windows will expel or pull in air. MACHINERY GROUP: subject to item Blowers, rotary, or Centrifugal Fans, see Note, item : Subs 1-8 Not Involved NOTE Does not apply on fans designed for: (1) expelling from an area, air, dust, gas, odors, smoke or other contaminants, or (2) introducing into an area, air from an outside source. For applicable provisions, see item 61900, Fans, exhaust or ventilating. Proposed Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item Fans, exhaust or ventilating, with or without heating elements or lighting fixtures, etc... Cancel; see item A-NEW NOTE Cancel; no further application NOTE Cancel; no further application. Subject 8, Page 1 of 5

48 SUBJECT 8 Proposed Classification Provisions Concluded Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item A-NEW Fans, NOI, including Exhaust or Ventilating Fans, see Note, item B-NEW, in boxes, crates or Packages 2044, 2046 or 2237, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 or greater B-NEW NOTE Exhaust or ventilating fans may be equipped with heating elements or lighting fixtures Fans, NOI, etc... Cancel; see item A-NEW NOTE Cancel; no further application NOTE Cancel; no further application. MACHINERY GROUP: subject to item Blowers, rotary, or Centrifugal Fans, see Note, item : Subs 1-8 No Change NOTE Does not apply on fans designed for: (1) expelling from an area, air, dust, gas, odors, smoke or other contaminants, or (2) introducing into an area, air from an outside source. For applicable provisions, see item A- NEW, Fans, NOI, including Exhaust or Ventilating Fans. Analysis Research Project 1340 This proposal is based on the information developed through Research Project The project was initiated in January 2018 in response to a report brought to the CCSB stating that the current provisions for exhaust or ventilating fans, as named in item 61900, are not reflective of the products transportation characteristics and may be improperly applied. Subsequently, the CCSB s review was expanded to include item 61920, which names fans, NOI. Hereinafter, these products will be referred to as fans. History of Provisions Provisions for exhaust or ventilating fans and fans, NOI, as named in items and 61920, respectively, were adopted from the rails and first appeared in LTL-1, effective April 1, Note, item first appeared in Supplement 7-A to NMFC LTL-1, effective October 30, No docket information was obtained. Note, item was established as a result of action taken on Docket 65, Subject 117 (September 1954). The Note first appeared in Supplement 8 to NMFC A-2, effective March 8, Subject 8, Page 2 of 5

49 SUBJECT 8 Notes, items and were established as a result of action taken on Docket 703, Subject 77 (May 1970). The Notes first appeared in Supplement 18 to NMFC A-12, effective June 30, The current provisions of items and were established as a result of action taken on Docket 933, Subject 11 (April 1993) and first appeared in Supplement 6 to NMF 100-T, effective October 9, The provisions have remained substantially unchanged to the present. About Fans The involved products are electric fans, including those fans with exhaust or ventilating capabilities. Examples of these products are shown below. Transportation Characteristics Density Overall, the information of record for fans includes 39,383 density observations submitted by a carrier, collected during CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 0.52 to pcf, with an overall average density of 5.97 pcf. When the data is evaluated on the basis of a proposed density break at 6 pcf, as shown in the table below, the resultant ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater 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 8, Page 3 of 5

50 SUBJECT 8 Handling As shown in the photo to the right, the involved products are typically tendered in boxes secured on lift truck skids or pallets, but may also be shipped in crates or one of the authorized numbered packages 2. When packaged fully enclosed in boxes, crates or one of the authorized numbered packages, handling will be comparable to that of other like-packaged freight. There have been no reports of unusual or significant handling concerns. Stowability When tendered in boxes, crates or one of the authorized numbered packages, a flat load-bearing surface and support for adjacent freight will generally be present. While some units may include shipper instructions or precautionary markings, such as Do Not Double Stack or This Side Up, there have been no reports of unusual or significant stowability considerations. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. With regards to claims, one carrier reported a claims ratio of 0.26% for fans moving under item from January through July No value information was obtained. Relationship to CCSB Policies and Guidelines CCSB policy calls for the amendment of classifications for commodities that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. CCSB policy also calls for combining descriptions embracing related commodities. As such, to address potential interpretation issues, and in the interest of clarification and simplification, it would be within CCSB policy to cancel items and with reference to a new item for Fans, NOI, including Exhaust or Ventilating Fans, as proposed. Additionally, a new Note would be established to clarify that exhaust or ventilating fans may be equipped with heating elements or lighting fixtures. CCSB policy also calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for fans shows that these products have a density range from 0.52 to pcf, with an overall average of 5.97 pcf, and no unusual or significant handling, stowability or liability characteristics. When commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density break at 6 pcf, the average densities and classes shown in the table on the following page emerge. 2 Fans have also been observed shipped wrapped and/or strapped on lift truck skids or pallets without being boxed or crated. Neither the present nor the proposed provisions authorize this form of tender. Subject 8, Page 4 of 5

51 SUBJECT 8 Density Group (pcf) Average Density (pcf) CCSB Minimum Average Density Guideline (pcf) Class Based on CCSB Density Guidelines Less than or greater It would be in keeping with CCSB policy and precedent to establish classes predicated on a density break at 6 pcf for the involved products 3. Notes, items 61902, 61904, and would be canceled as having no further application. In the interest of clarification and uniformity, Note, item would be amended to reference the proposed new item and the proposed new description. Precedent for this approach can be found in Docket , Subject 5 (June 2018), involving hosiery, including pantyhose, socks or stockings. No significant handling, stowability or liability concerns were reported and, as such, density was determined to be the primary transportation characteristic. While the densities were distributed throughout the range of 0.50 to pcf, a single density break at 6 pcf was proposed to provide a more accurate representation of the identified range in density. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AR, effective August 25, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 8, Page 5 of 5

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53 SUBJECT 9 Re: Mats, bathtub, shower stall, drainboard, sink or stove protector, plastic or rubber Item CCSB Contact: Ashley L. Gencarelli Telephone (703) gencarelli@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item Articles, viz.: Articles, NOI; [Other Articles Listed Not Involved.] In boxes, crates, drums or Packages 870, 1078, 1241, 1273, 1456, 2195, 2212, 2213, 2230 or 2459, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE Not Involved NOTE Not Involved NOTE Not Involved Mats, bathtub, shower stall, drainboard, sink or stove protector, in boxes Subject 9, Page 1 of 4

54 SUBJECT 9 Proposed Classification Provisions Item Description Class PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item Articles, viz.: Articles, NOI; Mats, bathtub, shower stall, drainboard, sink or stove protector; [Other Articles Listed No Change.] In boxes, crates, drums or Packages 870, 1078, 1241, 1273, 1456, 2195, 2212, 2213, 2230 or 2459, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE No Change NOTE No Change NOTE No Change Mats, bathtub, shower stall, drainboard, sink or stove protector, etc... Cancel; see item Analysis Research Project 1343 This proposal is based on the information developed through Research Project 1343, which was initiated in January 2018 to review the transportation characteristics of bathtub, shower stall, drainboard, sink or stove protector mats, as named in item Subject 9, Page 2 of 4

55 SUBJECT 9 History of Provisions The provisions for bathtub, shower stall, drainboard, sink or stove protector mats were established as a result of action taken on Docket 43, Subject 66 (November 1949) and first appeared in Supplement 6 to NMFC No. 10, effective March 14, The current class was established as a result of action taken on Docket 133, Subject 106 (March 1968). That proposal was approved as modified, and the provisions first appeared in Supplement 9 to NMFC A-10, effective December 23, The provisions have remained substantially unchanged to the present. About Bathtub, Shower Stall, Drainboard, Sink or Stove Protector Mats Bathtub, shower stall, drainboard, sink or stove protector mats come in a wide variety of shapes and sizes. They are used as a barrier on bare surfaces that can prevent slips or spills, contain messes, or protect areas against damage. Pictures of the involved mats are shown below. Transportation Characteristics Density The information of record on the involved mats includes 479 density observations submitted by a shipper and obtained from the CCSB s Density Study 1. The products range in density from 1.63 to pcf, with an average density of 8.71 pcf. The densities are distributed throughout the range. Handling and Stowability The involved mats are generally tendered in boxes secured on lift truck skids or pallets. There have been no reports of any unusual or significant handling or stowability problems. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. There have been no reports of claims, and no value information was obtained. 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 9, Page 3 of 4

56 SUBJECT 9 Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record indicates that the involved mats range in density from 1.63 to pcf, with an average density of 8.71 pcf. The involved articles exhibit no unusual or significant handling, stowability or liability characteristics and, as such, density is the governing characteristic in the assignment of classes. Under CCSB guidelines, an average density of 8.71 pcf is generally associated with class 110, which calls for a minimum average density of 8 pcf. However, CCSB policy further states that commodities exhibiting a wide density range not accurately reflected by a single overall average density may be assigned density-based classes, and where densities are distributed throughout the range, commodities may be assigned classes predicated on a full density scale. This proposal would cancel item with reference to item where classes are predicated on the CCSB s standard 11-subprovision density progression 2. Additionally, in the interest of clarity and uniformity, Mats, bathtub, shower stall, drainboard, sink or stove protector would be added to the viz. listing in item A similar approach was taken on Docket , Subject 19 (February 2018), involving fireplace inserts. Based on the information of record, and in keeping with CCSB policy and precedent, the provisions for fireplace inserts were canceled with reference to the densitybased provisions of item 69420, applying on related commodities, and Fireplace Inserts was added to the description of item The proposal was approved as docketed, and the changes first appeared in Supplement 1 to NMF 100-AR, effective April 28, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 2 Item provides the CCSB s standard 11-subprovision density scale, which includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 9, Page 4 of 4

57 SUBJECT 10 Re: Item (Rule) 680 Definition of Loose CCSB Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 680, Packing or Packaging General, to read as follows: ITEM 680 PACKING OR PACKAGING GENERAL General Sec. 1. (a) No Change. Sec. 1. (b) Unless otherwise provided for in the separate descriptions of articles, where classes are provided for 'loose' or 'in bulk,' such classes will also apply on the same articles when in packages; or if no packing or form of acceptance is mentioned, the classes will also apply on the same articles when loose or in packages. See also Secs. 5(a) and (b). Secs No Change. Definitions of the Terms 'In Packages' and Loose Sec. 5. (a) When the term 'in packages' is provided in connection with the separate descriptions of articles, such articles will be accepted for transportation in any container or in any other form tendered to carrier which will permit handling into or out of vehicles as units, provided such containers or tendered forms will render the transportation of freight reasonably safe and practicable so that it will withstand the normal rigors of the less-than-truckload environment. The term 'in packages' includes articles securely fastened to lift truck skids, pallets or platforms, or unitized quantities, but does not include articles 'in bulk,' 'loose,' 'on skids' or articles racked or braced in vehicles. Sec. 5. (b) The term loose is defined as freight that is not packaged, not unitized, not on skids and not securely fastened to lift truck skids, pallets or platforms. When the term loose is provided in connection with the separate descriptions of articles or where no packing or form of acceptance is specified, articles may be tendered loose for transportation only when the transportation of the articles is reasonably safe and practicable so that it will withstand the normal rigors of the less-than-truckload environment. Where necessary to afford adequate protection against damage, articles must be packaged or otherwise protected by packing forms or other packaging materials. Secs No Change. Subject 10, Page 1 of 2

58 SUBJECT 10 Analysis While the NMFC does not have a definition for the term loose, it has long been understood, or at least interpreted, as meaning freight that is not packaged, not unitized, not on skids and not securely fastened to lift truck skids, pallets or platforms. The CCSB has received reports from the CRC Packaging Subcommittee, as well as directly from carriers, questioning the definition of loose, and asking what is acceptable to be shipped loose and what protection may be required. Specifically, shippers are filing claims for loose freight that is being damaged from the normal rigors of the less-than-truckload environment. While these articles may be permitted to be shipped loose in the individual item descriptions, some level of protection may nevertheless be necessary to mitigate the chance of damage, including cosmetic damage. Such examples include power pumps, certain lamp posts or iron or steel pipe or tubing (see photo). Item (Rule) 680, Sec. 1(a) requires, in part, The minimum requirements notwithstanding, articles must be tendered for shipment in such a manner as to withstand the normal rigors of the less-than-truckload environment. Whether or not part of the specific requirements, protective packing forms or other packaging materials must be used where necessary to afford adequate protection against damage to the articles being shipped. In some instances, products that are shipped loose are very heavy, or have lengths exceeding eight feet 1, which requires the carrier to push and/or pull the freight into and out of vehicles, or during cross-dock operations, creating opportunity for damage. Additionally, damage from contact with adjacent freight can occur during transport. Relationship to CCSB Policies and Guidelines CCSB policies state the CCSB is to establish and maintain packaging rules and specifications 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. Therefore, it would be in keeping with CCSB policy to add a new paragraph to Sec. 5 of Item 680 to provide a definition of loose, which would also require the freight to be packaged or otherwise protected when necessary to withstand the normal rigors of the less-than-truckload environment. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies. 1 Item (Rule) 568, for Heavy or Bulky Freight Loading or Unloading, employs the threshold limit of exceeding 8 feet (96 inches) in greatest dimension as the measurement at which the consignor will perform the loading and the consignee will perform the unloading. Subject 10, Page 2 of 2

59 SUBJECT 11 Re: Jacks or Jackscrews CCSB Contact: Keith L. Charles, Jr. Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class TOOLS, OR PARTS NAMED: subject to item Jacks, cantilever, pneumatic or ratchet, or Jackscrews, NOI, not wheeled: Sub 1 Loose if weighing each less than 25 pounds Sub 2 In packages, or loose if weighing each 25 pounds or over Jacks, hydraulic, other than cantilever, not wheeled: Sub 1 In packages other than boxes or crates Sub 2 In boxes or crates Jacks, lifting, hydraulic, automobile servicing, wheeled, in boxes, see Note, item NOTE Applies only when handle has been removed from body and taken apart and placed in same shipping container with body Jacks, trailer tongue lifting, worm gear driven, wheeled, for trailers such as boat or camper, in boxes Jacks or Jackscrews, lifting, NOI, wheeled, see Note, item NOTE Will not apply on products known as pallet jacks or pallet lift trucks. See item for applicable provisions. Proposed Classification Provisions Item Description Class TOOLS, OR PARTS NAMED: subject to item A-NEW Jacks or Jackscrews, lifting, NOI, hydraulic, mechanical or pneumatic, wheeled or not wheeled, see Note, item B-NEW, in boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 12 but less than Sub or greater B-NEW NOTE Does not apply on pallet jacks or pallet lift trucks. For applicable provisions, see item Jacks, cantilever, pneumatic or ratchet, or Jackscrews, NOI, not wheeled, etc... Cancel; see item A-NEW Jacks, hydraulic, other than cantilever, not wheeled, etc... Cancel; see item A-NEW Jacks, lifting, hydraulic, automobile servicing, wheeled, etc... Cancel; see item A-NEW Subject 11, Page 1 of 5

60 SUBJECT 11 Proposed Classification Provisions Concluded Item Description Class TOOLS, OR PARTS NAMED: subject to item NOTE Cancel; no further application Jacks, trailer tongue lifting, worm gear driven, wheeled, for trailers such as boat or camper, etc... Cancel; see item A-NEW Jacks or Jackscrews, lifting, NOI, wheeled, etc... Cancel; see item A-NEW NOTE Cancel; see item B-NEW. Analysis Research Project 1272 This proposal is based on the information developed through Research Project 1272, which was initiated in January 2016 to investigate the transportation characteristics of jacks or jackscrews. History of Provisions The original provisions for jacks or jackscrews, as named in items and , were adopted from the rails, and first appeared in LTL-1, effective April 1, Item was established as a result of action taken on Docket 775, Subject 38 (July 1977). That proposal was approved as modified, and the provisions first appeared in Supplement 20 to NMF 100-D, effective February 25, The provisions of item , including Note, item , were established as a result of action taken on Docket 109, Subject 77 (July 1963) and first appeared in Supplement 3 to NMFC A-7, effective November 26, The provisions of item were established as a result of action taken on Docket 781, Subject 2 (January 1978) and first appeared in Supplement 7 to NMF 100-E, effective August 12, Note, item was established as a result of action taken on Docket , Subject 17 (November 2000) to clarify that the provisions of item Will not apply on products known as pallet jacks or pallet lift trucks, and directing the NMFC user to item for the applicable provisions. The Note first appeared in Supplement 2 to NMF 100-AA, effective January 27, The involved provisions have remained substantially unchanged to the present. Subject 11, Page 2 of 5

61 SUBJECT 11 About Jacks or Jackscrews Jacks or jackscrews are hydraulic, mechanical or pneumatic tools that use force to lift and/or support objects, predominately objects that may be of substantial weight. Jacks or jackscrews can also be utilized to relieve strain from a particular area where pressure is concentrated during lifting. They may come equipped with or without wheels, as well as with a fixed or removable handle. The involved products can vary in configuration and size, as shown in the photos below. Transportation Characteristics Density The information of record for the involved articles includes 18,998 density observations submitted by a carrier, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 1.52 to pcf, with an average density of pcf. The data can be divided into three density groupings of less than 12 pcf, 12 but less than 22.5 pcf, and 22.5 pcf or greater. When evaluated on the basis of these three density groupings, as shown in the table below, the resultant ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater 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 11, Page 3 of 5

62 SUBJECT 11 Handling The involved products are generally tendered for shipment in boxes or crates, but have also been observed tendered loose or in packages other than boxes or crates 2. When shipments are tendered in boxes or crates, as shown in the picture below, no unusual handling concerns have been identified. Stowability The stowability of jacks or jackscrews will vary depending on the manner in which they are tendered for shipment. When tendered in a box or crate, there is no indication of unusual or significant stowability considerations. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. One carrier reported a claims ratio of 2.09% for shipments moving under item in However, that carrier did not indicate which subprovision applied sub 1 of the item applies on jacks shipped in packages other than boxes or crates nor did it report any claims for any of the involved items in A shipper submitted information indicating a claims ratio of less than 1% annually. No information was obtained on the value per pound of these commodities. Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to be as clear as possible to help preclude interpretation disputes and also calls for combining descriptions embracing related commodities. To mitigate potential interpretation issues, and in the interest of clarification and simplification, this proposal would cancel items , , , and with reference to a new item for jacks or jackscrews. CCSB policy also calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for jacks or jackscrews shows that these products have a density range from 1.52 to pcf, with an overall average of pcf, and when packaged in boxes or crates, they exhibit no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of pcf is generally associated with class 70, which calls for a minimum average density of 15 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 12 and 22.5 pcf, the average densities and classes shown in the table on the following page emerge. 2 While some of the current provisions permit loose shipments or do not specify any packaging, the proposed provisions would require the involved articles to be tendered in boxes or crates. Subject 11, Page 4 of 5

63 SUBJECT 11 Average CCSB Minimum Average Class Based on CCSB Density Group (pcf) Density (pcf) Density Guideline (pcf) Density Guidelines Less than but less than or greater It would be in keeping with CCSB policy and precedent to establish classes predicated on density breaks at 12 and 22.5 pcf for jacks or jackscrews 3. Furthermore, to help ensure the products are 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, the proposed provisions would specify in boxes or crates. Additionally, Note, item would be canceled as having no further application. Note, item would be canceled with reference to a new Note attendant to the new item. Precedent for this approach can be found in Docket , Subject 10 (September 2016), involving refrigerant reclaiming or recovery machines, as named in item Density was determined to be the primary transportation characteristic since there were no significant handling, stowability or liability concerns reported. Two density breaks at 8 and 12 pcf were proposed to provide a more accurate representation of the identified density range of 2.40 to pcf. That proposal was approved as docketed, and the provisions first appeared in Supplement 4 to NMF 100-AP, effective December 10, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 11, Page 5 of 5

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65 SUBJECT 12 Re: Bathroom Medicine or Toilet Cabinets Item CCSB Contact: Larissa A. Franklin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class CABINETS, OR PARTS NAMED: subject to item Bathroom Medicine or Toilet, other than plastic, see Note, item 39232, with or without integral lighting fixtures, in Packages 1F, 3F or 5F NOTE Applies only on cabinets designed to be hung from or recessed in upper walls. Proposed Classification Provisions Item Description Class CABINETS, OR PARTS NAMED: subject to item Cabinets, bathroom medicine or toilet, other than plastic, see Note, item 39232, with or without integral lighting fixtures, in boxes or Packages 1F, 3F or 5F NOTE No Change. Analysis Research Project 1347 This proposal is based on the information developed through Research Project 1347, which was initiated in February of 2018 to review the transportation characteristics of bathroom medicine or toilet cabinets, as described in item Hereinafter, these products will be referred to as bathroom medicine cabinets. History of Provisions Provisions for bathroom medicine cabinets, with or without lighting fixtures, as now named in item 39230, were adopted from the rails in Due to reports of lighter densities for plastic bathroom medicine cabinets, the phrase other than plastic was added to the description as a result of action taken on Docket 137, Subject 18 (November 1968), and first appeared in Supplement 22 to NMFC A-10, effective July 1, The current class 100 and Note, item were established as a result of action taken on Docket 743, Subject 33 (May 1974). These changes first appeared in Supplement 1 to NMF 100-B, effective April 1, The current wording of Note, item was established as a result of action taken on Docket 763, Subject 7 (April 1976), and first appeared in Supplement 11 to NMF 100-C, effective November 5, Subject 12, Page 1 of 3

66 SUBJECT 12 The provisions have remained substantially unchanged to the present. About Bathroom Medicine Cabinets Bathroom medicine cabinets are cabinets intended to be recessed within walls or hung from walls in bathrooms to store various items, such as medications, toiletries and other personal care products. The cabinets involved in this proposal are generally made of wood or metal and may or may not have a mirrored surface. Some bathroom medicine cabinets also have built-in lighting fixtures. Examples of the involved products are depicted below. Transportation Characteristics Density The information of record includes 4,329 density observations submitted by shippers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 0.75 to pcf, with an average of 5.30 pcf. Over 84% of the figures fall between 2 and 8 pcf, indicating a large clustering of data around the average. Handling and Stowability Bathroom medicine cabinets are generally tendered in boxes secured on lift truck skids or pallets. They may also be tendered in complying F Packages. Some bathroom medicine cabinets are equipped with mirrors and/or lighting fixtures and would thus require a certain degree of care and attention when handling and stowing. However, there have been no reports of unusual or significant handling or stowability issues. 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 12, Page 2 of 3

67 SUBJECT 12 Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, nor do they appear likely to damage other freight. Although some bathroom medicine cabinets are considered fragile because they are equipped with certain components, such as mirrors or lighting fixtures, with proper interior and exterior packaging, there is, reportedly, minimal liability to damage. With regards to claims, one carrier reported a claims ratio of 2.52% in 2017; however, this same carrier also stated that there were no claims filed between January and July Another carrier indicated that there were no claims filed over the last two years. Limited value information indicates a range from $3.47 to $7.14 per pound, with an average value of $4.64 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Bathroom medicine cabinets exhibit a range of densities from 0.75 to pcf, with an average density of 5.30 pcf, and a preponderance of the density figures concentrated around the overall average. Though some negative handling, stowability and liability considerations were identified, they do not appear to significantly impact the transportability of these products; therefore, density is the governing transportation characteristic in the assignment of classes. An average density of 5.30 pcf is generally associated with class 175 under CCSB guidelines, which call for a minimum average density of 5 pcf. This proposal would thus assign class 175 to item Additionally, for clarification and uniformity, the noun Cabinets would be added to the description of item Furthermore, after review with the CCSB s packaging consultant, this proposal would authorize packaging in boxes for item A similar approach was taken on Docket , Subject 13 (June 2018), involving item , naming electric razors. No significant handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. Electric razors exhibited a range in density from 1.00 to pcf, with a significant concentration of density observations nearly 91% clustered around the overall average density of 5.81 pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal was approved as docketed, assigning class 175, and the change first appeared in Supplement 2 to NMF 100-AR, effective August 25, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 12, Page 3 of 3

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69 SUBJECT 13 Re: Paper Cups, Liners or Molds, baking, or Paper Cups, candy CCSB Contact: Allison L. Austin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class PAPER ARTICLES GROUP: subject to item Cups, baking, candy or charlotte russe, paper, in boxes, in cartons in crates or in Package 841: Sub 1 Glassine Sub 2 NOI Paper Goods or Articles, viz.: Doilies; Facial Tissues (Handkerchiefs); Gift Wrap Sets, see Note, item ; Napkins; Neck Strips; Paper Goods or Articles, NOI; Placemats; Tablecloths; In boxes, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE The following departures from packing requirements are permitted: 1. Doilies, neck strips, placemats or tablecloths may be shipped in Packages 215, 841, 2177 or Facial tissues (handkerchiefs) may be shipped in Packages 215, 841, 1252, 2065, 2177 or Napkins may be shipped in Packages 215, 841, 1252, 2177, 2278 or NOTE Not Involved. Subject 13, Page 1 of 4

70 SUBJECT 13 Proposed Classification Provisions Item Description Class PAPER ARTICLES GROUP: subject to item Cups, baking, candy or charlotte russe, paper, etc.... Cancel; see item Paper Goods or Articles, viz.: Cups, Liners or Molds, baking, or Cups, candy; Paper Goods or Articles, NOI; [Other Articles Listed No Change.] In boxes, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE The following departures from packing requirements are permitted: 1. No Change. 2. No Change. 3. No Change. 4. Baking cups, liners or molds or candy cups may be shipped in Package NOTE No Change. Analysis Research Project 1338 This proposal is based on the information developed through Research Project 1338, which was initiated in December 2017 to investigate the transportation characteristics of paper baking, candy or charlotte russe cups, as named in item Hereinafter, the involved products will be referred to as baking or candy cups. History of Provisions Provisions for baking or candy cups were adopted from the rails in The current provisions of item were established as a result of action taken on Docket 878, Subject 2 (December 1987) and first appeared in Supplement 9 to NMF 100-N, effective February 20, The provisions have remained substantially unchanged to the present. Subject 13, Page 2 of 4

71 SUBJECT 13 About Baking or Candy Cups The involved articles are paper products typically utilized in the preparation, packaging and/or display of bakery goods and candies. These products may vary greatly in size, shape and style. The bakery supplies industry uses an array of terms to describe products within the disposable bakeware category. This has resulted in interpretation questions regarding the application of item for products, such as baking molds and cake liners, that function similarly to but may not be clearly represented as baking cups. In these instances, CCSB opinions have held item , naming Paper Goods or Articles, NOI, applicable. Examples of some of the involved commodities are shown below. Transportation Characteristics Density The information of record includes 1,211 density observations submitted by a shipper and obtained from the CCSB s Density Study 1. The densities range from 0.97 to pcf, with an average of 7.34 pcf. The densities are widely distributed throughout the range. Handling and Stowability The information available relating to packaging indicates that baking or candy cups are generally shipped in boxes secured on lift truck skids or pallets. There have been no reports of unusual or significant handling or stowability problems. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. A responding shipper indicates minimal claims annually, and one carrier reports a yearto-date claims ratio of 0.34%. Only two value per pound observations, $2.40 and $2.56, were reported. 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 13, Page 3 of 4

72 SUBJECT 13 Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to reflect a commodity s known transportation characteristics. CCSB policy also calls for provisions to be as clear as possible to help preclude the potential for interpretation disputes. Information of record indicates that baking or candy cups range in density from 0.97 to pcf, with an average of 7.34 pcf, and exhibit no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of 7.34 pcf is generally associated with class 125, which calls for a minimum average density of 7 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established, and where densities are distributed throughout the range, commodities may be assigned classes predicated on a full density scale. Accordingly, this proposal would cancel the provisions of item with reference to item where classes are predicated on the CCSB s standard 11-subprovision density progression 2. Concurrently, item would be amended to add a listing for Cups, Liners or Molds, baking, or Cups, candy. A similar approach was taken on Docket , Subject 10 (May 2016), involving item for blankets. In that proposal, the provisions for blankets were canceled with reference to the full-scale density-based provisions of item 49390, and Blankets, NOI was added to the viz. listing in item The proposal was approved as docketed, and the change first appeared in Supplement 2 to NMF 100-AP, effective August 13, Additionally, Note, item would be amended to permit the involved products to be shipped in the currently authorized Package 841. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 2 Item provides the CCSB s standard 11-subprovision density scale, which includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 13, Page 4 of 4

73 SUBJECT 14 Re: Floor Sweeping or Spill Absorption Compounds CCSB Contact: Kyle R. Smith Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class Compounds, floor sweeping, not disinfectant: Sub 1 In inner containers in boxes or drums, or in pails in crates Sub 2 In bulk in packages Compounds, oil absorption, see Note, item 50272, in bags NOTE Provisions apply on compounds consisting of vegetable fiber or ground paper mixed with mineral products, asphalt, or petroleum derivatives, for absorbing waste or spilled oil from water, dry surfaces, vessels, machinery or containers. Proposed Classification Provisions Item Description Class Compounds, floor sweeping or spill absorption, other than disinfectant, see Note, item NEW, in bags, boxes or drums, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 15 but less than Sub or greater NEW NOTE Applies on compounds that trap or absorb dry or liquid waste from hard surfaces or bodies of water. Does not apply on chemical or oil absorption booms, pads, sweeps or other forms or shapes, as named in item Compounds, oil absorption, etc... Cancel; see item NOTE Cancel; no further application. Analysis Research Project 1321 This proposal is based on information developed through Research Project 1321, which was initiated in November 2017 to review the transportation characteristics of floor sweeping compounds or oil absorption compounds, as named in items and 50270, respectively. Subject 14, Page 1 of 4

74 SUBJECT 14 History of Provisions Provisions for floor sweeping compounds, as named in item 50170, were adopted from the rails and first appeared in LTL-1, effective April 1, The current provisions were established as a result of action taken on Special Docket No. 1 (issued July 20, 1949) and first appeared in NMFC A-1, effective July 10, The provisions have remained substantially unchanged to the present. The provisions of item 50270, including Note, item 50272, were established as a result of action taken on Docket 713, Subject 4 (May 1971) and first appeared in Supplement 5 to NMFC A-12, effective December 10, The provisions have remained substantially unchanged to the present. About Floor Sweeping or Oil Absorption Compounds Floor sweeping compounds can be made of a variety of different materials, including wax, oil, sand or sawdust. When scattered over an area, floor sweeping compounds will trap dust and other particulate, and, when swept, will prevent trapped particulate from becoming airborne. Oil absorption compounds are similar to floor sweeping compounds and are sometimes marketed as floor sweeping or spill absorption compounds. They can be formulated to absorb oil and other liquid spills from hard surfaces, or designed to be spread over oil spills in water. Oil absorption compounds can consist of cellulose, clay, silica, wax or similar materials, depending on the targeted spills or surface. Provisions for chemical or oil absorbing booms, pads, sweeps or other forms or shapes are found in item and are not included in this proposal. Subject 14, Page 2 of 4

75 SUBJECT 14 Transportation Characteristics Density The information of record includes 2,023 density observations submitted by carriers, shippers, observed firsthand on CCSB dock surveys and obtained from the CCSB Density Study 1. The products range in density from 1.82 to pcf, with an overall average density of pcf. When the data is evaluated based on density breaks at 15 and 22.5 pcf, the density ranges and averages in the table below emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling and Stowability The involved articles are generally tendered in bags, boxes or drums secured to lift truck skids or pallets. No significant handling or stowability issues have been reported. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. Shippers reported zero to ten claims annually. No carriers reported claims. The value per pound ranges from $0.14 to $1.54, with an average of $0.59 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for combining descriptions embracing related commodities, in the interest of clarification and simplification. This proposal would cancel the provisions of item with reference to item The description of item would be concurrently amended to read Compounds, floor sweeping or spill absorption, other than disinfectant, and the packaging provisions would be amended to include bags (from item 50270) and to remove reference to in pails in crates and In bulk in packages. THIS SPACE INTENTIONALLY LEFT BLANK 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 14, Page 3 of 4

76 SUBJECT 14 CCSB policy also calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for floor sweeping or oil absorption compounds shows that these products have a density range from 1.82 to pcf, with an overall average density of pcf, and no unusual handling, stowability or liability characteristics. Under CCSB guidelines, an average density of pcf is generally associated with class 70, which calls for a minimum average density of 15 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 15 and 22.5 pcf, the average densities and classes shown in the table below emerge. Density Group (pcf) Average CCSB Minimum Average Class Based on CCSB Density (pcf) Density Guideline (pcf) Density Guidelines Less than but less than or greater Based on the information of record, it would be within CCSB policy and precedent to amend item to provide classes predicated on density, with breaks at 15 and 22.5 pcf 2. Furthermore, a new Note would be established to clarify that item applies on compounds that trap or absorb dry or liquid waste from hard surfaces or bodies of water, and does not apply on chemical or oil absorption booms, pads, sweeps or other forms or shapes, as named in item Note, item would be canceled with no further application. A similar approach can be found in Docket , Subject 10 (September 2016), involving refrigerant reclaiming or recovery machines, as named in item Density was determined to be the primary transportation characteristic since there were no significant handling, stowability or liability concerns reported. Two density breaks at 8 and 12 pcf were proposed to provide a more accurate representation of the identified density range of 2.40 to pcf. That proposal was approved as docketed, and the provisions first appeared in Supplement 4 to NMF 100-AP, effective December 10, 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. Subject 14, Page 4 of 4

77 SUBJECT 15 Re: Garage Door Operators or Openers Item CCSB Contact: Keith L. Charles, Jr. Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Operators or Openers, garage door, with or without controls or hardware, in boxes or Package 2227: Sub 1 With drawbar, rail or trolley: Sub 2 SU Sub 3 KD Sub 4 Jackshaft or slide mount type Package 2227 When article is shipped SU in fiberboard boxes, fiberboard must test not less than 200 pounds, gross weight not to exceed 120 pounds, with no restriction applied to united inches. When article is shipped KD, power unit, with or without controls or hardware, must be shipped in fiberboard boxes testing not less than 200 pounds. Track, rail and hanger straps or supports may be shipped in packages or if each weighing 50 pounds or greater, may be shipped loose. Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Operators or Openers, garage door, with or without controls or hardware, in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 8 but less than Sub 3 12 or greater Cancel; no further application. Package 2227 Subject 15, Page 1 of 4

78 SUBJECT 15 Analysis Research Project 1341 This proposal is based on the information developed through Research Project 1341, which was initiated in January 2018 to investigate the transportation characteristics of garage door operators or openers, as named in item History of Provisions Provisions for garage door operators were established as a result of action taken on Docket 744, Subjects 21 and 22 (July 1974) on a joint disposition. Those proposals were approved as modified, and the provisions first appeared in Supplement 6 to NMF 100-B, effective May 23, Package 2227 was established as a result of action taken on Docket 755, Subject 31 (July 1975) and first appeared in Supplement 17 to NMF 100-B, effective December 24, The provisions have remained substantially unchanged to the present. About Garage Door Operators or Openers The involved products are automatic, stationary devices or units that function by lifting and lowering a garage door, and consists of a motor that moves a trolley 1. Garage door operators or openers work within a system and may run on chains, belts or threaded parts, with each of these methods of operation serving as the driving utility. Examples of these products are shown below. THIS SPACE INTENTIONALLY LEFT BLANK 1 (accessed August 2018) Subject 15, Page 2 of 4

79 SUBJECT 15 Transportation Characteristics Density The information of record includes 6,794 density observations submitted by a carrier, observed firsthand on CCSB dock surveys and gathered from the CCSB s Density Study 2. The densities range from 1.82 to pcf, with an overall average of pcf. When the data is evaluated on the basis of the three proposed density groupings, as shown in the table below, the resultant ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling and Stowability The involved articles are generally tendered in boxes that may be secured on lift truck skids or pallets. No significant handling or stowability issues have been reported. Liability Garage door operators or openers are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. Responding carriers reported minimal to no claims for the involved articles. No information was obtained on the value per pound of these commodities. Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for garage door operators or openers shows that these products have a density range from 1.82 to pcf, with an overall average of pcf, and no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of pcf is generally associated with class 85, which calls for a minimum average density of 12 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 8 and 12 pcf, the average densities and classes shown in the table on the following page emerge. 2 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 15, Page 3 of 4

80 SUBJECT 15 Average CCSB Minimum Average Class Based on CCSB Density Group (pcf) Density (pcf) Density Guideline (pcf) Density Guidelines Less than but less than or greater It would be in keeping with CCSB policy and precedent to establish classes predicated on density breaks at 8 and 12 pcf for garage door operators or openers, as named in item Additionally, a review of the presently authorized Package 2227 shows that it provides exceptions to the NMFC s packaging rules for fiberboard boxes and allows certain components to be tendered loose. These specifications do not appear to provide sufficient protection in today s LTL environment. Therefore, it would be in keeping with CCSB packaging policies to cancel Package 2227 as having no further application. A similar approach was taken on Docket , Subject 7 (May 2016), involving cable assemblies or harnesses, electrical wiring, NOI, as named in item Density was determined to be the primary transportation characteristic, since there were no significant handling, stowability or liability concerns reported. While the densities were distributed throughout the range of 1.24 to pcf, density breaks at 8 and 12 pcf were proposed to provide a more accurate representation of the distribution of the density observations. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AP, effective August 13, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 15, Page 4 of 4

81 SUBJECT 16 Re: Swabs, Swab Sticks or Swab-type Applicators Item CCSB Contact: Larissa A. Franklin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item Swabs, Swab Sticks or Swab-type Applicators, consisting of paper, plastic or wood sticks with cotton or synthetic fiber tips, singleor double-tipped, not saturated nor medicated, in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 10 or greater Proposed Classification Provisions Item Description Class DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item Swabs, Swab Sticks or Swab-type Applicators, consisting of paper, plastic or wood sticks with cotton or synthetic fiber tips, singleor double-tipped, not saturated nor medicated, in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 8 or greater Analysis Research Project 1326 This proposal is based on the information developed through Research Project 1326, which was initiated in November 2017 to review the transportation characteristics of swabs, swab sticks or swab-type applicators, as described in item History of Provisions The basic provisions of item were established as a result of action taken on Docket 104, Subject 47 (June 1962) and first appeared in Supplement 10 to NMFC A-6, effective October 23, The current description and classes were established as a result of action taken on Docket 932, Subject 12 (March 1993), and these changes first appeared in Supplement 1 to NMF 100-T, effective May 29, The provisions have remained substantially unchanged to the present. Subject 16, Page 1 of 3

82 SUBJECT 16 About Swabs, Swab Sticks or Swab-type Applicators Swabs, swab sticks or swab-type applicators are small rods or tubes with one or both ends covered with compact balls of cotton or synthetic fiber. Examples of the involved products are depicted below. Transportation Characteristics Density Overall, the information of record includes 2,174 density observations submitted by a carrier and a shipper, observed firsthand on a CCSB dock survey, and obtained from the CCSB s Density Study 1. The products range in density from 1.49 to pcf, with an overall average density of 7.12 pcf. When this data is evaluated based on a density break at 8 pcf, the following density ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling and Stowability The involved articles are generally tendered for shipment in boxes unitized on lift truck skids or pallets. Due to certain applications of these commodities (e.g. use in medical or personal care settings), care must be taken to avoid stowing these products with hazardous materials or other freight that may pose a contamination risk. However, there have been no reports of any unusual or significant handling or stowability problems. 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 16, Page 2 of 3

83 SUBJECT 16 Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, nor do they appear likely to damage other freight. These products may require extra care or attention to avoid contamination. There is no indication of a claims problem, and one value of $17.33 per pound was obtained. Relationship to CCSB Policies and Guidelines CCSB policies call for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record for swabs, swab sticks or swab-type applicators indicates that these products have a density range from 1.49 to pcf, with an overall average density of 7.12 pcf. Though some handling, stowability and liability considerations have been identified, they do not appear to significantly impact the transportability of these products. Therefore, density is the primary transportation characteristic in the assignment of classes. Per CCSB density guidelines, an average density of 7.12 pcf is generally associated with class 125, which calls for a minimum average density of 7 pcf. However, CCSB policies further state that when commodities exhibit a wide density range not accurately reflected by a single, overall average density, density-based classes may be established. The table below shows the results of the evaluation of the data of record based on the proposed density break at 8 pcf for item Density Group (pcf) Average Density CCSB Minimum Average Class Based on CCSB (pcf) Density Guideline (pcf) Density Guidelines Less than or greater Precedent for this approach can be found in Docket , Subject 13 (February 2018), involving air cleaners or air filtering machines. Density was determined to be the primary transportation characteristic, since there were no significant handling, stowability or liability concerns reported. While the densities were distributed throughout the range of 0.73 to pcf, a single density break at 8 pcf was proposed to provide a more accurate representation of the distribution of the density observations. That proposal was approved as docketed, and the provisions first appeared in Supplement 1 to NMF 100-AR, effective April 28, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. 2 The density provisions include reference to Item (Rule) 170, the inadvertence clause. Subject 16, Page 3 of 3

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85 SUBJECT 17 Re: Filters, liquid or gas, NOI, cartridge type, or tank type with fittings, iron or steel, other than water filters Item CCSB Contact: Kyle R. Smith Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FILTERS GROUP: subject to item Filters, liquid or gas, NOI, cartridge-type, or tank-type with fittings, iron or steel, other than water filters, in boxes or crates, see Note, item 69096: Sub 1 Empty Sub 2 Containing filter cartridges or filtering material necessary for operation NOTE Filters weighing each 400 pounds or more may be shipped on skids. Detached fittings must be in boxes or crates. Proposed Classification Provisions Item Description Class FILTERS GROUP: subject to item Filters, liquid or gas, NOI, cartridge type, or tank type with fittings, iron or steel, other than water filters: Sub 1 In boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 8 but less than Sub 4 12 or greater Sub 5 In packages other than boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 8 but less than Sub 8 12 or greater NOTE Cancel; no further application. Subject 17, Page 1 of 4

86 SUBJECT 17 Analysis Research Project 1314 Research Project 1314 was initiated in August 2017 to review the transportation characteristics of cartridge- or tank-type liquid or gas filters, as described in item History of Provisions The provisions of item 69095, including Note, item 69096, were established as a result of action taken on Docket 745, Subject 25 (September 1974) and first appeared in Supplement 13 to NMF 100-B, effective October 3, As a result of action taken on Docket , Subject 5 (May 2017) the restriction other than water filters was added to the item description. The change first appeared in Supplement 2 to NMF 100-AQ, effective August 5, The provisions have remained unchanged to the present. About Liquid or Gas Filters, NOI, Cartridge or Tank Type The involved products include cartridge-type or tank-type liquid or gas filters, not otherwise specified in the Classification. The involved item does not apply on filter elements or filtering media, nor on water filters. Examples are shown in the photos below. Transportation Characteristics Density The information of record includes 11,564 density observations submitted by a carrier, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 0.67 to pcf, with an overall average of pcf. The data can be divided into three density groupings of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater. When evaluated on the basis of these three density groupings, the ranges and averages shown in the table on the following page are calculated. 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 17, Page 2 of 4

87 SUBJECT 17 Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling The current provisions call for the involved filters to be tendered in boxes or crates 2. However, shipments have also been observed tendered on lift truck skids or pallets, with little or no protective packaging. Those articles shipped in boxes on lift truck skids or pallets, or in crates will not present unusual or significant handling considerations. However, when tendered on lift truck skids or pallets and not in boxes, a certain degree of extra care and attention will be required for them to be safely handled. Stowability When tendered in boxes or crates, a flat load-bearing surface will generally be present for loading other freight on top, and there will typically be lateral support for adjacent freight. However, some negative stowability issues have been identified for shipments not in boxes or crates. Filters tendered in packages other than boxes or crates may not provide a regular load-bearing surface for top freight or lateral support for adjacent freight. Additionally, when loading the handling unit inside the vehicle, the lack of packaging may limit the type of freight that can be safely stowed adjacent to it. This can result in increased time and effort on the part of the carrier to properly structure the load, including the use of load decks and/or dunnage, to minimize the potential for damage. Liability The involved filters are not perishable, unusually susceptible to theft or hazardous in nature. When tendered for shipment fully enclosed in a box or a crate, filters are not unusually liable to damage or likely to damage other freight. However, when tendered in packages other than boxes or crates, with little or no protective packaging, these products may exhibit a greater susceptibility to be damaged or damage other freight. No claims data was reported, and no value information was obtained. 2 Note, item allows filters weighing each 400 pounds or more to be shipped on skids, and detached fittings must be in boxes or crates. Subject 17, Page 3 of 4

88 SUBJECT 17 Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record for cartridge- or tanktype liquid or gas filters shows a range in density from 0.67 to pcf, with an average of pcf. Under CCSB guidelines, an average density of pcf is generally associated with class 100, which calls for a minimum average density of 9 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. Moreover, in this instance, research has identified significant negative handling, stowability and liability characteristics, particularly when the articles are not packaged in boxes or crates, and these characteristics must also be considered, in accordance with CCSB policies. The table below relates the information of record to the proposed density groupings and CCSB guidelines for the proposed classes when tendered in boxes or crates, and a oneclass adjustment for when the articles are tendered in packages other than boxes or crates, to address the identified negative handling, stowability and liability characteristics. Density Group (pcf) Average Density (pcf) CCSB Minimum Average Density Guideline (pcf) Class Based on CCSB Density Guidelines Class Adjustment for Handling, Stowability and Liability Considerations Less than but less than or greater Based on the information of record, it would be in keeping with CCSB policy and precedent to amend item by assigning classes based on packaging and density 3. Note, item would be canceled with no further application. A similar approach was taken on Subject 11 of Docket (February 2018), involving item , naming power tools, other than power hand tools. Density was determined to be the primary transportation characteristic when those products were shipped in boxes, crates or Package When tendered in other packages, the articles presented additional handling, stowing and liability concerns. Accordingly, classes were predicated on packaging and density, assigning respectively higher classes for power tools, other than power hand tools, tendered for shipment in packages other than boxes, crates or Package That proposal was approved as docketed, and the provisions first appeared in Supplement 1 to NMF 100-AR, effective April 28, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 17, Page 4 of 4

89 SUBJECT 18 Re: Spice Racks CCSB Contact: Larissa A. Franklin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class HOUSEHOLD UTENSILS GROUP: subject to item Cabinets or Racks, spice, wood, containing glass bottles or jars, in boxes RACKS: subject to item * Racks and Related Articles, viz.: Corrals, shopping cart (Cart Corrals), see Note, item ; Racks, NOI; Swimming Pool Cover Racks or Reels; In packages or Package 410, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE Not Involved NOTE Not Involved. *Published in Supplement 1 to NMF 100-AR, effective April 28, Proposed Classification Provisions Item Description Class HOUSEHOLD UTENSILS GROUP: subject to item Cabinets or Racks, spice, wood, containing glass bottles or jars, etc... Cancel; see item Subject 18, Page 1 of 4

90 SUBJECT 18 Proposed Classification Provisions Concluded Item Description Class RACKS: subject to item Racks and Related Articles, viz.: Spice Racks, see Note, item NEW; [Other Articles Listed No Change.] In packages or Package 410, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE No Change NOTE No Change. NEW NOTE Spice racks may be shipped with complement of empty bottles or jars in same package. Analysis Research Project 1359 This proposal is based on the information developed through Research Project 1359, which was initiated in May of 2018 to investigate the transportation characteristics of wooden spice cabinets or racks containing glass bottles or jars, as named in item Hereinafter, the involved products will be referred to as spice racks. History of Provisions The provisions of item were established as a result of action taken on Docket 129, Subject 47 (July 1967). That was a shipper proposal to establish a new item for wooden spice racks shipped in conjunction with glass bottles or jars. Cabinets was included to address the possibility of having spice racks with attached doors. The item first appeared in Supplement 22 to NMFC A-9, effective February 16, 1968, and the provisions have remained substantially unchanged to the present. Subject 18, Page 2 of 4

91 SUBJECT 18 About Spice Racks A spice rack is utilized to store and organize various spices and seasonings. Spice racks come in a variety of sizes and styles and can be made from various materials as well, though the provisions of item are restricted to wooden construction. Spice racks may also be sold together with empty bottles or jars, as is required in the provisions of item ; however, spice racks today may also be sold without the accompaniment of bottles or jars. Spice racks that do not meet the requirements of item are classified under the density-based provisions of item , naming Racks, NOI. Although the provisions of item allow for spice cabinets, research indicates that these types of commodities are overwhelmingly referred to and marketed as spice racks. Examples of the products embraced by item are depicted below. Transportation Characteristics Density The information of record includes 240 density observations obtained from the CCSB s Density Study 1 on products reported to be moving under item The products range in density from 2.46 to pcf, with an average density of pcf. The densities are widely distributed throughout the range. Handling and Stowability Spice racks are typically tendered secured on lift truck skids or pallets 2. There have been no reports of any unusual or significant handling or stowability problems. Liability The involved products are not perishable, unusually susceptible to theft, hazardous in nature, nor do they appear likely to damage other freight. Though glass bottles or jars are inherently fragile, with proper interior and exterior packaging, there is, reportedly, minimal liability to damage. There is no indication of any claims issues, and no value information was obtained. 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. 2 While it is unclear from the information of record how these products are packaged for shipment, the present provisions of item require spice racks to be packaged in boxes and the provisions of item require shipments to be in packages. Subject 18, Page 3 of 4

92 SUBJECT 18 Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that spice racks range in density from 2.46 to pcf, with an average density of pcf. Though some liability considerations were identified, they do not appear to negatively affect the transportability of these products. Also, no evidence of negative handling or stowability characteristics was found; thus, density is the governing characteristic in the assignment of classes. An average density of pcf is generally associated with class 92.5, which calls for a minimum average density of 10.5 pcf. However, CCSB policy further states that commodities exhibiting a wide density range not accurately reflected by a single overall average density may be assigned density-based classes, and where densities are distributed throughout the range, commodities may be assigned classes predicated on a full density scale. Furthermore, CCSB policy also calls for providing uniformity in provisions addressing the same or similar circumstances published in conjunction with different items. Spice racks that do not meet the specific requirements of item are presently classified under the full-scale density-based provisions of item Therefore, canceling the provisions of item with reference to item , as proposed, is in keeping with CCSB policy. CCSB policy also calls for eliminating excess or unclear wording and combining item descriptions of related commodities. As explained previously, the term spice cabinets is not used to describe the type of products discussed in this proposal. Therefore, eliminating the reference to spice cabinets, and adding Spice Racks to the viz. listing of item , as proposed, would be in keeping with CCSB policy. Additionally, a new Note attendant to item would be established, stating that spice racks may be shipped with complement of empty bottles or jars in the same package. Precedent for this approach can be found in Subject 22 of Docket (June 2018), involving item 49505, which applied on certain cloth or fabric table napkins and tablecloths. It was proposed to cancel item with reference to the full-scale density-based provisions of item 49390, which applied on cloth or fabric table napkins and tablecloths not meeting the requirements of item 49505, and Napkins, table and Tablecloths were proposed to be added to the viz. listing in item The proposal was approved as docketed, and the change first appeared in Supplement 2 to NMF 100-AR, effective August 25, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 3 Item provides the CCSB s standard 11-subprovision density scale, which includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 18, Page 4 of 4

93 SUBJECT 19 Re: Item (Rule) 110, Sec. 5 Definition of a Shipment CCSB Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Classification Resource Committee Present Classification Provisions ITEM 110 DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES The following definitions will apply when such terms are used in this Classification or in tariffs governed by this Classification. When different definitions are provided for the same terms in connection with rates, classes, rules or other provisions, such definitions will take precedence. Secs Not Involved. Sec. 5. Unless otherwise provided in carriers tariffs, a shipment consists of a lot of freight tendered to a carrier by one consignor at one place at one time for delivery to one consignee at one place on one bill of lading. Secs. 5. (a)-23. Not Involved. Proposed Classification Provisions ITEM 110 DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES The following definitions will apply when such terms are used in this Classification or in tariffs governed by this Classification. When different definitions are provided for the same terms in connection with rates, classes, rules or other provisions, such definitions will take precedence. Secs No Change. Sec. 5. Unless otherwise provided in carriers tariffs, a shipment consists of a tender of freight to a carrier by a consignor at one place at one time for delivery to a consignee at one place at one time on one bill of lading. Secs. 5. (a)-23. No Change. Analysis and Relationship to CCSB Policies and Guidelines This proposal was docketed by the Classification Resource Committee (CRC) to update the language in Item (Rule) 110, Sec. 5, which provides a definition of the term shipment, by removing the term a lot and replacing it with the term a tender, in the interest of clarification. Also, additional wording changes are proposed in the interest of clarification and simplification. CCSB policy calls for the updating of classification rules to be consistent with current motor carrier practice and clear as to intent. This proposal, as docketed, is in keeping with that policy. Subject 19, Page 1 of 1

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95 SUBJECT 20 Re: Package 2394 CCSB Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ATHLETIC GOODS GROUP: subject to item * Athletic or Sporting Goods, viz.: Boards, water sports, NOI, see Notes, items and 15524; [Other Articles Listed Not Involved.] In boxes or crates, see Note, item 15522, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater * NOTE The following departures from packing requirements are permitted: 1-3. Not Involved. 4. Sailboards may be shipped in Package Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved. Package 2394 Sailboard must be wrapped with a material formed by the lamination of two plies of plastic film which form air bubble encapsulations between. Wrapped board must then be enclosed within a plastic film bag of not less than 6 mil thickness. Mast must be adequately wrapped to provide necessary protection. Parts or accessories necessary for assembly of complete sailboard must be in boxes complying with Item 222. *Published in Supplement 2 to NMF 100-AR, effective August 25, Subject 20, Page 1 of 3

96 SUBJECT 20 Proposed Classification Provisions Item Description Class ATHLETIC GOODS GROUP: subject to item Athletic or Sporting Goods, viz.: Boards, water sports, NOI, see Notes, items and 15524; [Other Articles Listed No Change.] In boxes or crates, see Note, item 15522, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE The following departures from packing requirements are permitted: 1-3. No Change. 4. Not currently used. 5. No Change NOTE No Change NOTE No Change NOTE No Change. Cancel; no further application. Package 2394 Analysis and Relationship to CCSB Policies and Guidelines Package 2394 permits sailboards, which are classified in item 15520, to be wrapped in bubble wrap and placed in a plastic film bag for shipment. This package 1 was established as a result of action taken on Docket 834, Subject 17 (May 1983) and first appeared in Supplement 11 to NMF 100-J, effective December 3, The specifications have remained unchanged to the present. There is no evidence that this method of packaging is still being utilized for sailboards. However, carriers have reported other boards for water sports being shipped in similar-type packaging that is resulting in damage and difficultly in handling and stowing in today s LTL environment. 1 The involved package was tested under Test Shipment Permit (TSP) T Subject 20, Page 2 of 3

97 SUBJECT 20 CCSB packaging policies state that packaging specifications should 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. Based on a review of the specifications, this packaging method will not provide adequate protection in today s LTL environment. Therefore, it would be in keeping with CCSB policies and precedent to cancel Package 2394 as having no further application. Concurrently removing the reference to the package from Note, item 15522, as proposed, would also be in keeping with CCSB policies. Subject 20, Page 3 of 3

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99 SUBJECT 21 Re: Obsolete Provisions Items 82844, 98110, and CCSB Contact: Matthew S. Brutzman Telephone (703) William F. Mascaro Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FURNITURE PARTS GROUP: subject to item Chair Backs, laminated paperboard or pulpboard not upholstered, nested, banded to pallets or skids Hat Blocks, wooden, in boxes, crates or drums IRON OR STEEL: subject to item Sponge Iron Briquettes or Pellets, having value only for melting purposes, in packages Japan Wax Substitute, consisting of fatty acid esters and petroleum wax, in burlap bags Proposed Classification Provisions Item Description Class FURNITURE PARTS GROUP: subject to item Chair Backs, laminated paperboard or pulpboard not upholstered, nested, etc... Cancel; believed to be obsolete Hat Blocks, wooden, etc... Cancel; believed to be obsolete IRON OR STEEL: subject to item Sponge Iron Briquettes or Pellets, having value only for melting purposes, etc... Cancel; believed to be obsolete Japan Wax Substitute, consisting of fatty acid esters and petroleum wax, etc... Cancel; believed to be obsolete Subject 21, Page 1 of 3

100 SUBJECT 21 Analysis Provisions for chair backs, as named in item 82844, were established as a result of action taken on Docket 741, Subject 65 (January 1974) and first appeared in Supplement 17 to NMF 100-A, effective December 20, The provisions have remained substantially unchanged to the present. Historical information indicates that laminated paperboard or pulpboard chair backs were typically used to create cardboard or paper chairs and could be bent into different shapes. However, Internet searches failed to identify any domestic shippers or manufacturers, and there is no evidence of movement in the less-than-truckload (LTL) environment. Provisions for hat blocks, as named in item 98110, were adopted from the rails and first appeared in LTL-1, effective April 1, 1936, at a rating equivalent to the current class 85. The provisions have remained substantially unchanged to the present. Hat blocks traditionally were a solid piece of material used to shape, hold or display hats. An response from a potential manufacturer indicates that they do not ship via LTL carrier. Provisions for sponge iron briquettes or pellets, as named in item , were established as a result of action taken on Docket 89, Subject 106 (June 1959) and first appeared in Supplement 28 to NMFC A-4, effective February 11, The provisions have remained substantially unchanged to the present. Sponge iron briquettes or pellets are pressed in a machine to decrease the surface area and increase the productivity and energy conservation of plain iron powder. However, Internet searches failed to identify any domestic shippers, and no shippers describing their products as sponge iron briquettes or pellets have been identified. Provisions for Japan wax substitute, as named in item , were established as a result of action taken on Docket 60, Subject 42 (September-October 1953) and first appeared in Supplement 1 to NMFC A-2, effective August 7, The provisions have remained substantially unchanged to the present. Japan wax substitute was used as an alternative to Japan wax, also known as sumac wax, which is a water-insoluble solid with a gummy feel. It was used in products such as candles, furniture polishes, soaps, cosmetics and adhesives. However, Internet searches failed to identify any domestic shippers, and no shippers marketing their products as Japan wax substitute have been identified. Furthermore, the CCSB s Density Study 1 from 2015 to 2018 revealed the information shown in the table on the following page, indicating that the provisions may be obsolete. It is believed that the four noted observations may be the result of misclassification. 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 21, Page 2 of 3

101 SUBJECT 21 Item CCSB Density Study Observations (Since 2015) Relationship to CCSB Policies and Guidelines CCSB policy calls for the removal of obsolete provisions in the interest of clarification and simplification. Based on the information of record, canceling the provisions of items 82844, 98110, and as obsolete, as proposed, is in keeping with CCSB policy and precedent. Subject 21, Page 3 of 3

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103 I DOCKET , SUBJECT 7 DEFERRED SUBJECT Re: Self-Supporting (Rigid) Fiberglass Reinforced Plastic (FRP) Sheet Packaging CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: Crane Composites, Florence, Kentucky Present Classification Provisions Item Description Class PLASTIC MATERIALS, OTHER THAN EXPANDED, GROUP: subject to item Sheet or Plate, NOI, self-supporting (rigid), other than with formed interior cells, cavities or flutes, see Note, item , other than in rolls or coils, in boxes, crates or Packages 248, 1029, 2187, 2207 or 2310: Sub 1 In authorized packages on A-frame shipping racks, see Note, item Sub 2 In authorized packages not on A-frame shipping racks; or on lift truck pallets or skids; see Note, item : Sub 3 Exceeding 220 united inches Sub united inches or less, subject to Item 170 and having a density in pounds per cubic foot of: Sub 5 Less than Sub 6 30 or greater NOTE Applies whether or not corrugated, crimped, channeled or ribbed, but not otherwise curved, bent or formed. Does not apply on sheet or plate with formed interior cells, cavities or flutes NOTE Not Involved NOTE Not Involved. Proposed Classification Provisions Item Description Class PLASTIC MATERIALS, OTHER THAN EXPANDED, GROUP: subject to item Sheet or Plate, NOI, self-supporting (rigid), other than with formed interior cells, cavities or flutes, see Note, item , other than in rolls or coils, in boxes, crates or Packages 248, 1029, 2187, 2207, 2310 or NEW: Sub 1 In authorized packages on A-frame shipping racks, see Note, item Sub 2 In authorized packages not on A-frame shipping racks; or on lift truck pallets or skids; see Note, item : Sub 3 Exceeding 220 united inches Sub united inches or less, subject to Item 170 and having a density in pounds per cubic foot of: Sub 5 Less than Sub 6 30 or greater Dkt , Sbj. 7, Page 1 of 5

104 I DOCKET , SUBJECT 7 DEFERRED SUBJECT Proposed Classification Provisions Concluded Item Description Class NOTE No Change NOTE No Change NOTE No Change. Package NEW (1) ARTICLES: Self-supporting (rigid) fiberglass reinforced plastic (FRP) sheet may be shipped palletized and protected as specified. (2) PROTECTIVE PACKAGING: (a) Articles must be stacked on lift truck skid or pallet meeting all requirements set forth in Item 265 and sized so that articles do not overhang the lift truck skid or pallet deck. (b) One sheet of oriented strand board (OSB) or ½-inch thick drywall must be placed on the lift truck skid or pallet deck. (c) One of the following materials must be placed on top and cover the full dimensions of the stack of articles: (i) ½-inch thick drywall sheet; (ii) inch honeycomb sheet using 33-pound paper facing, with a strength rated between 22 and 30 psi; OR (iii) High density polyethylene (HDPE) foam sheet having a density of 20 pcf. (d) Nonexpanded plastic L-shaped corner protectors must be screwed into the ends of the lift truck skid or pallet at all four corners. (e) Edges of articles must be protected by fiberboard measuring not less than 2 x 6 inches and stapled to the lift truck skid or pallet. (i) Handling units with drywall or foam sheet used as top protection must have edge boards extending the full length and width of the handling unit. (ii) Handling units with honeycomb sheet used as top protection must have edge boards extending not less than 24 inches from each corner. (3) STRAPPING REQUIREMENTS: All handling units must be secured together with not less than two embossed plastic straps, measuring 0.75 x inch and having a tensile strength of 1,900 pounds, in both the length and width directions. (4) MARKINGS: Handle with Care, a label indicating fork extensions must be used, and other precautionary markings, as applicable, must be on at least two sides of the packaged article. (See Item 682.) Dkt , Sbj. 7, Page 2 of 5

105 I DOCKET , SUBJECT 7 DEFERRED SUBJECT Analysis This proposal was submitted by Crane Composites to add a new numbered package for their self-supporting (rigid) fiberglass reinforced plastic (FRP) sheets, which are classified in item Hereinafter these products will be referred to as FRP sheets. Information from the proponent s website 1 and furnished by the proponent indicates that the FRP sheets are sold to manufacturers in different markets and can be utilized as decorative wall coverings, RV exterior side panels, trailer side skirts, or RV or trailer roof panels. An example of the involved articles is shown on the right. This proposal was initially considered by the CCSB at its public meeting on June 12, 2018 in Alexandria, VA. Prior to the meeting, the CCSB received unsubstantiated reports of damage claims and package failure. Since this was a shipper proposal, the CCSB had not had an opportunity to further research the use and effectiveness of this package. In consideration of this information and to allow the CCSB time to investigate these reports, the CCSB voted to defer disposition of this proposal to its next meeting, scheduled for October 16, Prior to the original docketing of the proposal, the proponent conducted LTL test shipments with their FRP sheets in the different variations of the proposed package from Kentucky to California and back. Only slight damage to the packaging was noted in these shipments, and no damage occurred to the FRP sheets. In response to the unconfirmed reports of damage, the proponent reported 2 that all of the versions of this packaging [are] either being used or [have] been used with no issues relating to any spikes in exception freight (damages/claims). The two packaging designs utilizing the drywall top and the honeycomb top are being used for most shipments. The proponent reports that they are being received well by LTL carriers and delivered without exception when handled correctly by LTL providers. inquiries to carriers have yielded no confirmed reports of damage claims for this product and packaging. 1 (accessed April 2018) 2 dated July 19, 2018 Dkt , Sbj. 7, Page 3 of 5

106 I DOCKET , SUBJECT 7 DEFERRED SUBJECT Proposed Package Design The proponent s FRP sheets are stacked on appropriately sized lift truck skids or pallets and protected with various packaging materials. All handling units have either a sheet of oriented strand board (OSB) or a sheet of ½ thick drywall 3 that is placed directly on top of the lift truck skid or pallet deck. The top of the stack of FRP sheets may be protected by a ½ thick drywall sheet, a thick honeycomb sheet, or a high density polyethylene (HDPE) foam sheet having a density of 20 pcf. See photos below. ½ Thick Drywall Top Honeycomb Top 20 pcf HDPE Foam Top As shown in the left and middle photos below, nonexpanded plastic corner protectors are screwed into the lift truck skid or pallet at all four corners, and the perimeter of the handling unit is fully or partially protected by fiberboard measuring not less than 2 x 6, which is secured in place with staples. A minimum of two straps in each direction secure the handling unit together for transport, as shown in the right photo below. Drywall or Foam Top with Full Edge Board Protection Honeycomb Top with Partial Edge Board Protection 4 Finished Handling Unit The proponent reports that the FRP sheets may be 96 or 144 inches in length, and the handling unit height varies, depending on the quantity of FRP sheets being shipped. The handling units are marked Handle with Care, and they also include a notice to carriers to use fork extensions. 3 While drywall is generally not used as a packaging material, the proponent states that the drywall adds necessary stiffness and rigidity to the handling unit. The FRP sheets come off the manufacturing line warm and are placed directly onto a lift truck skid or pallet. When the sheets are warm, they can change shape, and drywall (or OSB) prevents the sheets from dipping between the deck boards. Also, these handling units may be stacked high, which can equate to a lot of weight on the bottom handling unit. Additionally, the drywall sheets come appropriately sized for these handling units and do not need to be cut. 4 The proponent has indicated that the handling units with honeycomb have edge boards extending not less than 24 inches from each corner, as a cost-saving measure. There is no indication that the lack of full edge protection has resulted in damage to the FRP sheets. Dkt , Sbj. 7, Page 4 of 5