CCSB Contact: Allison L. Austin Telephone (703) Item Description Class

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1 Re: Mattresses, Box Springs or Waterbeds Item CCSB Contact: Allison L. Austin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FURNITURE GROUP: subject to item Mattresses, NOI, see Notes, items and 79553; Upholstered Box Springs; or Waterbeds, see Note, item 79554; in Packages 5F, 10F, 47F or 154F, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 4 or greater NOTE Applies only on mattresses having a thickness of not less than three inches equipped with a cover made of cloth or plastic film or sheeting NOTE Crib mattresses may be shipped in Package 36F NOTE Applies only on waterbeds consisting of a mattress (foam, cellular, expanded or sponge plastic or rubber pad, integral water cylinders or bladder, and plastic liner; with fabric covering) with or without a pedestal or platform. Package 36F Mattresses must be individually wrapped in Kraft paper, basis weight not less than 60 pounds. Container must be singlewall corrugated box complying with all requirements of Item 222 for boxes testing not less than 200 pounds, except gross weight must not exceed 125 pounds, dimension limit must not exceed 120 united inches and container must be closed by strapping with not less than three metal straps, not less than 3 /8 x inch. Protection must be afforded under straps to prevent them from cutting container; OR Container may be closed by not less than three straps of reinforced paper tape consisting of two layers of sulphate Kraft paper laminated and reinforced with fiberglass netting, the tape having tensile strength not less than 50 pounds per inch of width in cross direction and not less than 70 pounds per inch of width in machine direction. Tape must be not less than 1 1 /2 inches in width, must completely encircle container, and overlap upon itself not less than 4 inches; OR Slotted boxes may be closed with a pressure-sensitive or gummed filament tape that meets the requirements of Item 222. Tape must be not less than 3 /4 inch in width. Not less than two strips of tape must be used on each end on top and bottom, and not less than two strips across both top and bottom sections of boxes with strips extending not less than 5 inches over score line National Motor Freight Traffic Association, Inc. Subject 1, Page 1 of 8

2 Present Classification Provisions Concluded Package 47F In bags or fully enclosing wrappers made of low density polyethylene film complying with the following minimum requirements: Thickness (Mils) 4 Drop Dart Impact Resistance ASTM D (grams) Tensile Properties ASTM D882-A 2700 (psi) Percent Elongation ASTM D882-A 300 (%) Puncture Propagation of Tear ASTM D (Grams) Box springs must be protected by pads made of one ply indented paper, minimum basis weight 28 pounds per 1,000 square feet, laminated to one ply of cross laminated high density monoaxially oriented polyethylene film of minimum 2.5 mils nominal thickness, or pads complying with Note, item 79024, or corrugated fiberboard testing not less than 125 pounds. Pads must be secured to bottom of box spring, extend full length of sides, around corners and not less than ten inches along ends. Pads must extend not less than two inches over top and bottom edges of box spring. Corrugated fiberboard need only extend to the top edge of box spring. Bag or wrapper must be securely closed and packages may be heat shrunk. Gross weight must not exceed 115 pounds and dimensions must not exceed 150 united inches (length, width and depth added). Package 154F Mattresses may be shipped when completely enclosed within linear low density polyethylene (LLDPE) plastic film; an inner film bag of 4 mil thickness, a film boot covering designated transportation or handling edge having a thickness of 3 mils and an outer film bag of 8 mil thickness, providing for a total of 12 mil thickness overall, with a total 15 mil thickness protecting the transportation end. INNER FILM BAG 4 mil LLDPE plastic film having the following properties: Tensile Strength (MD/TD): 5500/5700 psi (ASTM D-882) Elongation (MD/TD): 1000/1100% (ASTM D-882) Dart Drop: 900 grams (ASTM D-1709A) Elmendorf Tear (MD/TD): 1600/1600 grams, minimum (ASTM D-1922) INNER FILM BOOT 3 mil LLDPE plastic film having the following properties: Tensile Strength (MD/TD): 5400/5000 psi (ASTM D-882) Elongation (MD/TD): 850/800% (ASTM D-882) Dart Drop: 450 grams (ASTM D-1709A) Elmendorf Tear (MD/TD): 850/1450 grams, minimum (ASTM D-1922) OUTER FILM BAG 8 mil LLDPE plastic film having the following properties: Tensile Strength (MD/TD): 4500/4850 psi (ASTM D-882) Elongation (MD/TD): 800/900% (ASTM D-882) Dart Drop: 1100 grams (ASTM D-1709A) Elmendorf Tear (MD/TD): 2000/3200 grams, minimum (ASTM D-1922) CLOSURE Securely taped. Subject 1, Page 2 of National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Item Description Class FURNITURE GROUP: subject to item A-NEW Mattresses, compressed and rolled, in boxes, see Note, item B-NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 7 or greater Mattresses, NOI; Upholstered Box Springs; or Waterbeds, see Note, item 79554; in Packages 5F or 10F, see Note, item B-NEW 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. When so tendered, articles may be shipped in Packages 47F or 154F NOTE Cancel; no further application NOTE Cancel; no further application NOTE No Change. Cancel; no further application. No Change. No Change. Analysis Package 36F Package 47F Package 154F Research Project 1368 This proposal is based on information developed through Research Project 1368, which was initiated in May 2018 to address interpretation issues and investigate the transportation characteristics of mattresses, box springs or waterbeds, as embraced by item History of Provisions Provisions for mattresses or box springs were adopted from the rails and first appeared in LTL-1, effective April 1, Note, item was established as a result of action taken on Docket 137, Subject 41 (November 1968) and first appeared in Supplement 33 to NMFC A-10, effective April 23, National Motor Freight Traffic Association, Inc. Subject 1, Page 3 of 8

4 Docket 907, Subject 13 (November 1990) was a proposal that sought to amend item to provide class 300, amend the description to name waterbeds, and concurrently establish a Note to define waterbeds. Information on that record indicated a range in densities from 1.58 to pcf, and an average density of 3.56 pcf. A one-class adjustment from density guidelines was proposed to address identified handling and stowability concerns. The proposal was approved as modified, but the disposition was appealed by the International Sleep Products Association (ISPA) 1. ISPA submitted a counterproposal Docket 908, Subject 14 (December 1990) to alternatively establish two subprovisions predicated on density, with a break at 4 pcf. That proposal was approved as modified, the result of a compromise, and the provisions first appeared in Supplement 7 to NMF 100-Q, effective March 30, The provisions have remained substantially unchanged to the present. About Mattresses, Box Springs or Waterbeds This proposal includes various articles utilized as beds or as principal components of beds, including mattresses, box springs, and waterbeds. The mattress-in-a-box," a newer category of products, generally involves compressing and roll-packing a mattress to fit into a small bag or box. For example, a typical king-size mattress (76 x 80 x 10 inches) may be compressed to fit in a 18 x 18 x 44-inch box. While originally designed as an e-commerce direct-to-consumer product, the compressed and rolled mattress market has expanded to include a presence in brick-and-mortar retail stores. Reports have suggested that compressed and rolled mattresses possess distinct transportation characteristics from other types of mattresses. There have also been interpretive questions regarding compressed and rolled mattresses vis-à-vis the thickness requirement in Note, item While the Note does not specify, CCSB opinions have generally held that the requirement pertains to the thickness of the product when in use. When established, Note, item was intended to aid in distinguishing between pads and mattresses. However, this line of demarcation does not address some circumstances. For example, a crib mattress may be less than 3 inches thick. Hereinafter, for purposes of evaluating the transportation characteristics, the involved products will be referred to as mattresses, NOI or compressed and rolled mattresses. 1 As modified, item would provide class 250. Subject 1, Page 4 of National Motor Freight Traffic Association, Inc.

5 Transportation Characteristics Density Overall, the information of record includes 71,241 density observations submitted by shippers and a carrier, collected during CCSB dock surveys and obtained from the CCSB s Density Study 2. Mattresses, NOI, range in density from 0.13 to 8.06 pcf, with an average density of 3.10 pcf. Over 94% of the figures fall between 1 and 6 pcf, with over 71% clustered between 2 and 4 pcf. Compressed and rolled mattresses range in density from 2.10 to pcf, with an average density of 7.75 pcf. In contrast to mattresses, NOI, the figures are more widely distributed throughout the range. When the data is analyzed with a density break at 7 pcf, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling Mattresses, NOI, are generally tendered in bags or boxes, which may or may not be secured on lift truck skids or pallets. When tendered on lift truck skids or pallets, the use of appropriately sized pallets can facilitate handling and mitigate the chance for damage. The lack of palletization can affect the handling of mattresses, NOI. Articles that are not secured on lift truck skids or pallets often require manual handling, limiting the carrier s ability to handle the freight in an efficient and timely manner. Many of the larger units or sizes are also quite bulky. For example, the photo to the right is a shipment of a queen-size mattress in a fiberboard box measuring 81 x 62 x 12 inches. The size and configuration of such shipments will necessitate extra personnel to safely handle, and result in additional time and effort in crossdock operations. Information indicates that compressed and rolled mattresses are typically tendered in bags or boxes secured on lift truck skids or pallets, which can be readily handled with mechanical equipment. 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 National Motor Freight Traffic Association, Inc. Subject 1, Page 5 of 8

6 Stowability When placed flat on a lift truck skid or pallet, as shown in the photo to the right, mattresses, NOI, may appear to provide a flat load-bearing surface, but due to the compressive nature of the product, carriers are extremely limited as to the type of freight that may be stacked on top. Articles that are not secured on lift truck skids or pallets will require top loading or tying or strapping to the side of the vehicle to structure and secure the load and maximize vehicle utilization. While mattresses, NOI, may provide some lateral support, additional care and attention will be required to ensure that only compatible freight is loaded adjacent to the products to prevent damage. Compressed and rolled mattresses are tendered in bags or boxes that are usually palletized for shipment. Due to their compressed size, these products provide greater ability for carriers to readily structure a load and enable better usage of vehicle cube when compared with stowing mattresses, NOI. Liability Mattresses, NOI, are not perishable, unusually susceptible to theft, hazardous in nature, or prone to damage other freight. They may be susceptible to damage; however, this susceptibility will vary depending upon the manner in which the article is tendered for shipment. For example, carriers indicate damage claims when articles are shipped in bags that are not secured on lift truck skids or pallets. These products are more prone to rips occurring in the bag allowing the product to become soiled. One carrier reports a 2018 claims ratio of 0.18% for products moving under item Additionally, responding shippers report one to six claims annually. The value per pound ranges from $2.50 to $42.86, with an average value of $11.81 per pound. Similarly to mattresses, NOI, many of the liability elements do not appear to significantly impact the evaluation of compressed and rolled mattresses. However, some extra care and attention should be given to avoid puncturing the bag or box, which, if compromised, could affect the integrity of the compressed roll. No specific information regarding claims or value for these commodities was obtained. Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to reflect a commodity s known transportation characteristics. The information of record indicates that mattresses, NOI, range in density from 0.13 to 8.06 pcf, with an average density of 3.10 pcf, and a preponderance of the density figures concentrated around the overall average. Under CCSB guidelines, an average density of 3.10 pcf is generally associated with class 250, which calls for a minimum average density of 3 pcf. Subject 1, Page 6 of National Motor Freight Traffic Association, Inc.

7 However, in this instance, research has identified significant negative handling, stowability and liability characteristics, and these characteristics must also be considered, in accordance with CCSB policy. These factors have been detailed in this analysis and include, but are not limited to, the need for additional care and attention to safely handle the freight, including the need for extra personnel, the difficulty or inability to stack top freight and difficulty loading adjacent freight, and the increased susceptibility to damage. In such situations, classification precedent has been to assign a class higher than that called for under CCSB density guidelines. This proposal would assign mattresses, NOI, class 300, a one-class increase from the product s average density, to account for the added handling, stowability and liability considerations. A similar approach was taken on Docket , Subject 1 (May 2011), involving pneumatic tires, as named in item Pneumatic tires were assigned a class higher than that associated with the CCSB density guidelines to account for the identified negative handling and stowing considerations. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AK, effective July 23, When the information of record for compressed and rolled mattresses is evaluated, the densities are shown to be more widely distributed throughout the range. Additionally, many of the negative handling, stowability and liability characteristics associated with mattresses, NOI, appear to be mitigated. When commodities exhibit a range in density not accurately represented by a single class, CCSB policy states that density-based provisions may be established. As shown in the table below, the data can be divided into two density groupings of less than 7 pcf, and 7 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 Establishing a new item, naming Mattresses, compressed and rolled, with a single density break at 7 pcf, would be in keeping with CCSB policy and precedent 3. Precedent for this approach can be found in Docket , Subject 9 (September 2013), involving skateboards, as named in item 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 2.44 to pcf, a single density break at 7 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 4 to NMF 100-AM, effective December 14, The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 1, Page 7 of 8

8 To mitigate interpretation issues, Note, item would be canceled with no further application. To provide additional packaging requirements, a new Note would be established and referenced by both items requiring those articles tendered on lift truck skids, pallets or platforms to be securely fastened to and not overhang the edges of the lift truck skid, pallet or platform deck. When so tendered, articles may be shipped in Packages 47F or 154F. Furthermore, a review of the presently authorized numbered packages by the CCSB s Packaging Consultant indicates that Package 36F may no longer provide sufficient protection in today s LTL environment. Therefore, it would be in keeping with CCSB packaging policy to cancel Package 36F and Note, item as having no further application. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 1, Page 8 of National Motor Freight Traffic Association, Inc.