DOCKET JANUARY 2013

Transcription

1 DOCKET JANUARY 2013 A public meeting on National Motor Freight Classification provisions will be held on January 29, 2013 at: The Westin San Diego Hotel 400 West Broadway San Diego, California ISSUED: December 13, 2012

2 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET On Tuesday, January 29, 2013, 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 Westin San Diego Hotel, 400 West Broadway, San Diego, California 92101, commencing at 11:00 am. 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 staff contact and the identity of the proponent. Section II of this docket provides notice of classification changes made necessary by law, by order of a regulatory body or for clarification. 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 Section I herein, including how to contact the proponent, are contained in a Public Docket File. The public files are available online without charge at They are organized by docket and subject numbers, and each file is indexed for ease of reference. Interested persons who do not have Internet access can obtain the public docket file for a particular proposal from the staff contact, subject to a charge for copying and transmitting the document(s) requested. Commodity Classification Standards Board ccsb@nmfta.org Chairman Joel L. Ringer Member Member Member George M. Beck Daniel E. Horning William F. Mascaro Member Donald A. Newell 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 is welcome to attend the meeting and/or submit a statement relating to the transportation characteristics of the product(s) involved or relevant to packaging materials or methods in connection with proposed packaging amendments. Statements should include any underlying studies, supporting data and other pertinent information. Written submissions will be included in the respective public docket file. Decisions on docketed proposals will be based on the information contained in the public docket file. Any person may become a Party of Record to a docketed proposal by submitting a written request prior to the meeting. The proponent(s) of a proposal and anyone who attends the meeting in connection with a proposal or submits a written statement prior to the meeting will be registered as a party of record to that proposal. Parties of record to a docketed proposal will receive a disposition of the proposal and will be entitled to seek reconsideration or arbitration should they disagree with that disposition. (One does not have to be a party of record to request reconsideration.) 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 staff contact involved. To schedule an appearance at the meeting, or if you require further information, please get in touch with the staff 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 or arbitration is sought in accordance with the CCSB s rules. The supplement is scheduled to be issued on March 21, 2013, with an effective date of April 20, Future CCSB Dockets Docket Docket Docket Closing Date March 28, 2013 July 18, 2013 Docket Issue Date April 18, 2013 August 8, 2013 CCSB Meeting Date June 3, 2013 September 23, 2013 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 Barriers, door or window, detention or security Boxes, cooling, hand portable, expanded plastic... 8 Burners, boiler, furnace or commercial or industrial baking oven... 4 C Cans, waste or refuse, sheet steel... 9 Chests, cooling, or Coolers, hand portable, expanded plastic... 8 Containers, liquid or beverage serving, hand portable, expanded plastic... 8 D Determination of Density Item (Rule) 110, Sec Displays, video, computer or multimedia... 1 Doors or Door Sections or Grilles, garage or commercial or industrial building... 6 Doors, partition, steel and wire combined Doors, screen E Electrical Switch Boxes, Conduit Outlet Boxes or Outlet Box Covers, steel H Hand Tools, other than power... 3 Holders, waste or refuse, sheet steel or cast concrete... 9 I Ice Buckets, expanded plastic... 8 Item (Rule) 110, Sec. 8, Determination of Density K Kits, expendable aspirating, administration or transference... 2 Kits, inpatient or outpatient care or treatment... 2 Kits, maternity... 2 M Monitors, video, computer or multimedia... 1 O Oil, Water, Gas Well Group Outlet Boxes or Outlet Box Covers, electrical, steel P Partitions or Partition Doors, steel and wire combined R Receptacles, waste or refuse, sheet steel or cast concrete... 9 S Screen Doors or Window Screens Screens, door or window, detention or security Sets, expendable aspirating, administration or transference... 2 Siding, plastic Sprayers, boiler, furnace or commercial or industrial baking oven... 4 Stone Blocks, Pieces or Slabs... 7 Switch Boxes, electrical, steel T Televisions (TVs)... 1 Tools, hand, other than power... 3 V Vaporizers, boiler, furnace or commercial or industrial baking oven... 4 Page iii

5 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET INDEX OF SUBJECTS (PROPOSALS) DESCRIPTION SUBJECT DESCRIPTION SUBJECT W Washers (Washing Machines) or Washer-extractors, laundry, other than household... 5 Wastebaskets, sheet steel... 9 Water Wheels and Parts Well Boring or Drilling Machines Window Screens Page iv

6 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET

7 SUBJECT 1 Re: Televisions (TVs) or Video, Computer or Multimedia Monitors or Displays Staff Contact: Nathan D. Ripke Telephone (703) ripke@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item Televisions (TVs) or Video or Multimedia Monitors or Displays, NOI, including LCD or Plasma Televisions (TVs), Monitors or Displays, see Notes, items and 63324, in boxes or Packages 231, 809, 829, 979, 2320 or 2396, having a screen size measured diagonally of: Sub 1 40 inches or greater Sub 2 Less than 40 inches NOTE Televisions, monitors or displays named in the items making reference to this Note may be compatible with computers as well as video equipment. But monitors or displays intended for use exclusively with computers, and sold expressly as computer monitors or displays, are classified per item , naming 'Machines, Systems or Devices, data processing, or units that form components of data processing machines, systems or devices.' NOTE Not Involved Televisions (TVs), projection type, without integral screen, see Note, item 63323, in boxes... Not Involved THIS SPACE INTENTIONALLY LEFT BLANK Subject 1, Page 1 of 10

8 SUBJECT 1 Present Classification Provisions Concluded Item Description Class MACHINERY GROUP: subject to item Business or Office: subject to item * Machines, Systems or Devices, data processing, or Components, Parts or Peripherals thereof, see Note, item , viz.: Computers, including Personal Computers, Laptops, Notebooks or Tablets, or Components, Parts or Peripherals thereof, NOI; Machines, Systems or Devices, data processing, or Components, Parts or Peripherals thereof, NOI; [Other Articles Listed Not Involved.] In boxes, crates or Packages 2050, 2253, 2254, 2286 or 2291, released to a value not exceeding $25.00 per pound, 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 Provisions do not apply on cellular or radio telephones, including smartphones. For cellular or radio telephones, including smartphones, see item 62820, Radio-telephone Transmitting or Transmitting and Receiving Sets, for provisions based on released value, and item 62850, Radiotelephones, cellular (Cellular Telephones), for provisions not based on released value. *Published in Supplement 4 to NMF 100-AL, issued on November 1, 2012 with an effective date of December 1, Subject 1, Page 2 of 10

9 SUBJECT 1 Proposed Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item Televisions (TVs) or Video, Computer or Multimedia Monitors or Displays, NOI, see Note, item 63324, in boxes or Packages 231, 809, 829, 979, 2320 or 2396: Sub 1 In authorized packages as specified in Note, item NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 4 but less than Sub 4 8 or greater Sub 5 In authorized packages other than as specified in Note, item NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 4 but less than Sub 8 8 or greater NEW NOTE Applies when the shipping package serves also as the package for product display or sales purposes and when damage to the package itself, including cosmetic damage, will result in a claim, and bills of lading and shipping orders are so notated. The shipping package must also be marked to indicate that any damage to the package will result in a claim NOTE Cancel; no further application NOTE No Change Televisions (TVs), projection type, without integral screen, in boxes... No Change MACHINERY GROUP: subject to item Business or Office: subject to item Machines, Systems or Devices, data processing, or Components, Parts or Peripherals thereof, see Note, item , viz.: Computers, including Personal Computers, Laptops, Notebooks or Tablets, or Components, Parts or Peripherals thereof, NOI; Machines, Systems or Devices, data processing, or Components, Parts or Peripherals thereof, NOI; [Other Articles Listed No Change.] In boxes, crates or Packages 2050, 2253, 2254, 2286 or 2291, released to a value not exceeding $25.00 per pound, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Subs 1-11 No Change NOTE No Change. Subject 1, Page 3 of 10

10 SUBJECT 1 Proposed Classification Provisions Concluded Item Description Class NOTE Does not apply on: (1) Cellular or radio telephones, including smartphones. For cellular or radio telephones, including smartphones, see item 62820, Radiotelephone Transmitting or Transmitting and Receiving Sets, for provisions based on released value, and item 62850, Radiotelephones, cellular (Cellular Telephones), for provisions not based on released value. (2) Video, computer or multimedia monitors or displays. For Video, Computer or Multimedia Monitors or Displays, see item Analysis Research Project 1149 Research Project 1149 was initiated in January of 2012 to review the current transportation characteristics of televisions (TVs) or video or multimedia monitors or displays. Hereinafter, these products will be referred to as TVs, monitors or displays. A total of 329 potential manufacturers or shippers of TVs, monitors or displays and 27 associations believed to represent those companies, were sent questionnaires in March and May of Of the companies contacted, 23 responded that they do not manufacture or ship TVs, monitors or displays, 21 questionnaires were returned as undeliverable, and seven companies provided information; however, not all the information was usable. One association provided usable information, while six association questionnaires were returned as undeliverable, and five associations stated they do not represent companies of the involved products. Additional information of record was developed through CCSB dock surveys and carrier-submitted Shipment Information Forms. History of Provisions The provisions of item were established as a result of action taken on Docket , Subject 3 (May 2005) with subprovisions based on screen size. TVs, video or multimedia monitors or displays having a screen size of 40 inches or greater were assigned class 200 (sub 1), while screen sizes of less than 40 inches were assigned class 125 (sub 2). Information on that record included direct-view (picture tube or CRT) TVs or monitors, rear projection TVs, LCD TVs or monitors, but not plasma TVs, monitors or displays, which were, at the time, specifically named elsewhere in the Classification. Overall density information ranged from 1.64 to pcf, with an average of 5.40 pcf. Furthermore, TVs, monitors or displays with screen sizes of 40 inches or greater had an average density of 4.01 pcf and presented negative handling, stowing and liability characteristics. Screen sizes of less than 40 inches had an average density of 7.90 pcf with more favorable handling, stowability and liability characteristics. That proposal was approved as modified, and the provisions first appeared in Supplement 3 to NMF 100-AE, effective July 23, Subject 1, Page 4 of 10

11 SUBJECT 1 Docket , Subject 14 (June 2007) was a proposal by Panasonic Corporation of North America, Hitachi America, LTD and Phillips Consumer Electronics to amend former item 63322, naming plasma TVs, monitors or displays from a single class 250 to create subprovisions based on screen size with classes ranging from 200 to 125. Information from that record revealed plasma TVs ranged in density from 1.78 to 8.06 pcf, with an average of 5.36 pcf. Handling and stowing concerns were noted. Plasma TVs were to be kept in an upright position and at times required more than one person for loading and unloading. Some had precautionary markings, and some required blocking and bracing. The three proponents reported claims ratios of 10%, 8% and 5% while the average value per pound was $ That proposal was approved as modified, canceling item with reference to item 63321, assigning class 200 to screen sizes 40 inches or greater and class 125 to screen sizes less than 40 inches. This change first appeared in Supplement 3 to NMF 100-AG, effective August 25, As a result of action taken on Docket , Subject 6 (June 2007) item was amended to specifically name LCD TVs, monitors or displays for clarification purposes. Approved as docketed, the change first appeared in Supplement 3 to NMF 100-AG, effective August 25, Item has remained unchanged to the present. The current provisions of Note, item are the result of action taken on Docket , Subject 3 (August 2000). That proposal was to clarify that the provisions for TVs, monitors or displays apply on products that may be compatible with computers as well as video equipment; but monitors or displays intended for use exclusively with computers, and sold expressly as computer monitors or displays, are classified per item , naming Machines, Systems or Devices, data processing, or units that form components of data processing machines, systems or devices. Approved as docketed, those changes first appeared in Supplement 6 to NMF 100-Z, effective October 28, About TVs, Monitors or Displays Information of record encompasses numerous commodities represented as TVs or video, computer or multimedia monitors or displays. In today s market, the involved commodities predominately consist of a flat panel screen that displays an image through the use of different lighting technology, including LCD, LED, DLP and Plasma (PDP). These products are much thinner and lighter than direct-view (picture tube or CRT) products, which are not included on this record 1. Throughout research it was also found that computer monitors or displays being shipped via LTL motor carrier service today do not function exclusively as computer monitors. These commodities are equipped with multimedia or video functionality making them more than just a computer monitor. Pictures of the involved products are shown on page 6. 1 Old or used direct-view (picture tube or CRT) TVs, monitors or displays, including those destined for disposal, may still be moving via LTL motor carrier service; however, no information in regard to these products has been obtained. Subject 1, Page 5 of 10

12 % of Figures in Interval CCSB DOCKET SUBJECT 1 Flat Panel Television Flat Panel Multimedia Monitor or Display Transportation Characteristics Density The information of record contains 386 density observations ranging from 0.67 to pcf, with an average density of 5.96 pcf. Based on the frequency distribution of the figures below, the data can be divided into three density groupings of less than 4 pcf, 4 but less than 8 pcf, and 8 pcf or greater. Frequency Distribution 25% 20% 23% 19% 23% 18% 15% 10% 7% 8% 5% 1% 1% 0% 0% 0% 0% Density Intervals (pcf) When the data is evaluated based on the three density groups, the following ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Percentage of Figures Less than % 4 but less than % 8 or greater % Handling and Stowability TVs, monitors and displays require special care and attention in handling and stowing so as to avoid damage. These products are tendered to the carrier in boxes that may or may not be secured on lift truck skids or pallets, or in plastic boxes that Subject 1, Page 6 of 10

13 SUBJECT 1 provide forklift entry 2. Palletized units that do not fully occupy the pallet deck may present stowing concerns in that they may not provide a regular load-bearing surface for top freight or lateral support for adjacent freight. In this regard, information of record indicates that TVs, monitors or displays tendered in this manner exhibit lower densities than that of palletized units that do fully occupy the pallet deck. Regardless, heavy freight should not be loaded on top of these products to avoid damage. Pictures of TVs, monitors or displays fully occupying the pallet deck are shown below. TVs, monitors or displays tendered to the carrier in boxes not on lift truck skids or pallets may present negative handling characteristics. Larger, non-palletized TVs, monitors or displays are generally more difficult to handle; however, they may present a lesser stowing concern than palletized shipments not fully occupying the pallet deck. The pictures below show two separate shipments of the same 80-inch TV. In the shipment on the left each TV is strapped to a pallet and does not fully occupy the respective pallet deck. The shipment on the right is not palletized, and the TV is strapped to the sidewall of the trailer. 2 One shipper of monitors or displays for tractors ships their products in plastic boxes. This type of packaging seems to be an exception rather than the industry standard; however, such information is included on this record. Subject 1, Page 7 of 10

14 SUBJECT 1 Also, shippers have noted that special care should be taken when handling and stowing TVs, monitors or displays. Information of record indicates pictorial markings advising the carrier to Vertical Stack Only, Do Not Lay On Side, Top Load Only and Do Not Stack shipments. Other instructions to the carrier include Shock Watch Handle With Care and Do Not Break Down Skids. Liability TVs, monitors or displays are susceptible to damage due to their inherent fragility. With regards to claims, one member carrier reported a claims ratio of 0.04%, while another carrier estimated their claims ratio to be around 5%. A third carrier stated that they do not track claims by commodity; however, one of their largest customers, who is a frequent shipper of TVs, has a claims ratio of 4% of revenue, well above the 1% threshold deemed typical for LTL shipments. An insignificant amount of information with regard to theft was reported on this record, and value per pound, which provides a measure of potential carrier liability, ranges from $8.57 to $65.22, with an average of $ One carrier reported that the most frequent type of claim filed on TVs is for box damage. Even the slightest damage to a box may result in a refusal and return. In most cases, a shipper will generally charge between $50 and $100 per box if the TV remains in otherwise good order. This statement is supported by claims information submitted by a major shipper of TVs. Seventy-five percent of claims filed by this shipper in a one-year period were for box damage, with an average of $ per claim. The picture below provides an example of damage to a box that serves both as the outer package to protect the TV, monitor or display in transit and the retail package, or shelfready package, for consumer purchase. TVs, monitors or displays shipped in shelfready boxes are subject to special damages, i.e. the potential liability increases, as any damage to the box may result in a claim for the package only. In most instances, shelf-ready packaging is easily identifiable, albeit, many shippers are not advising the carrier at the time of shipment of the need for special care and attention in handling and stowing. Currently, there are no such requirements in item In the picture on the left, the consignee refused the order due to cosmetic damage to the package, and the carrier was charged a repackaging fee. Subject 1, Page 8 of 10

15 SUBJECT 1 Relationship to CCSB Policies and Guidelines CCSB policies state existing classifications should be amended to reflect changes in transportation characteristics. Research Project 1149 was initiated to determine if the transportation characteristics of TVs, monitors or displays have changed. The 386 density observations of record range from 0.67 to pcf, with an average density of 5.96 pcf. An average density of 5.96 pcf is generally associated with class 175, per CCSB density guidelines, which call for a minimum average density of 5 pcf. However, since the densities are distributed throughout the range, the density data has been evaluated based on breaks at 4 and 8 pcf. The density averages and associated classes that emerge are shown below. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines CCSB Density Guideline (pcf) Less than but less than or greater The proposed density breaks tend to address the handling and stowing concerns observed in TV, monitor or display shipments, as the lower-density shipping units also tend to exhibit the more significant handling and stowing issues. However, the negative liability characteristics of these products are not addressed. Liability has long been a concern for carriers with respect to TVs, monitors or displays and other electronic goods. In this regard, one of the primary functions of packaging is to protect the freight. If the package is damaged and the freight is undamaged, then the package has done its job. When a shipping package also serves as a shelf-ready box for product display or consumer purchase, carriers are required to take extra care when handling and stowing these products to avoid cosmetic damage to the package. If there is damage to the box, but not the product itself, the consignee may refuse the shipment, and the carrier may be charged a repackaging fee. Such measures are not typically required for general boxed freight. With respect to commodities that exhibit less-than-favorable handling, stowability or liability characteristics, classification precedent has been to assign a class one or two classes higher than what would generally be called for under the CCSB density guidelines. TVs, monitors or displays shipped in shelf-ready boxes are subject to special damages, but many shippers are not advising the carrier at the time of shipment of the need for special care and attention in handling and stowing since the current provisions of item do not require it. Therefore, it would be in keeping with CCSB policies to amend item by establishing classes based on whether or not the TVs, monitors or displays are tendered in shelfready packaging and on density 3. Shipments where damage to only the package will result in a claim would be assigned one class higher than that called for by the average density of each density group due to the risk of special damages associated with shelf-ready boxes. The table on page 10 details the classes proposed. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 1, Page 9 of 10

16 SUBJECT 1 Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines One-Class Adjustment for Liability Less than but less than or greater A new Note would be added to clarify the application of the provisions and to require the shipper to give notice of the special nature of this freight to the carrier at the time of shipment on the shipping papers and on the packaging. Throughout research it was also found that computer monitors or displays being shipped via LTL motor carrier service today do not function exclusively as computer monitors. As previously mentioned, these commodities are equipped with multimedia or video functionality making them more than just a computer monitor. Therefore, it would be in keeping with CCSB policies to add the term Computer to the description of item Since the CCSB holds the opinion that the commodities outlined in this proposal are classified under item 63321, it would be in keeping with CCSB clarification policy to cancel Note, item with no further application and remove its reference from items and Concurrently, Note, item would be amended to state that the provisions of item do not apply on video, computer or multimedia monitors or displays. Since the majority of TVs, monitors or displays employ LCD or plasma technology in today s market, the reference to LCD or Plasma Televisions (TVs), Monitors or Displays within the description of item is unnecessary. It would be in keeping with CCSB policy to remove said reference from item Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy. Subject 1, Page 10 of 10

17 SUBJECT 2 Re: Kits, inpatient or outpatient care or treatment; Kits, maternity; or Kits or Sets, expendable aspirating, administration or transference Item Staff Contact: Daniel E. Horning Telephone (703) horning@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item Kits, inpatient or outpatient care or treatment, NOI, see Note, item 56791; Kits, maternity, see Note, item 56792; or Kits or Sets, expendable aspirating, administration or transference, with empty plastic collecting or holding containers, or without containers; in boxes, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 5 or greater NOTE Applies on kits for use in doctors offices, hospitals, clinics, nursing homes or other medical institutions containing a mixture of three or more of the following: expendable medical instruments, expendable medical treatment accessories, or other articles for the care or treatment of the individual; with or without chemicals, drugs or medicines, other than narcotics NOTE Applies on kits consisting of sanitary pads or pads of similar design and construction and expendable accessories such as bedding pads, facial cleansing tissues, paper towels, sanitary belts, plastic shower caps, plastic gloves, swabs and bottles. THIS SPACE INTENTIONALLY LEFT BLANK Subject 2, Page 1 of 6

18 SUBJECT 2 Proposed Classification Provisions Item Description Class DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item Kits, inpatient or outpatient care or treatment, NOI, see Note, item 56791; Kits, maternity, see Note, item 56792; or Kits or Sets, expendable aspirating, administration or transference, with empty plastic collecting or holding containers, or without containers; in boxes, 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 Applies on kits consisting of bottles, maternity garments, sanitary pads or related accessories. Analysis This proposal is based on information developed through Research Project 1154 involving various kits or sets as named in item The project was initiated in February 2012 to develop current information on the transportation characteristics of these products and to determine if the provisions are properly reflective of the nature of goods moving in commerce today. Research Project 1154 During the project, questionnaires were sent to 157 potential manufacturers or shippers and 26 trade associations related to the medical kits or sets industry. Mailings were sent in March 2012, and for non-respondents, a second, follow-up letter was sent in May Additional contacts were sent letters in June From those questionnaires, usable information was received from two companies, while 12 questionnaires were either returned as undeliverable or the companies were not involved. Responses were received from two of the associations indicating that they did not represent manufacturers or shippers involved in the survey. Subject 2, Page 2 of 6

19 SUBJECT 2 Additional information was developed through the CCSB Density Study 1, CCSB dock surveys and carrier-submitted reports. History of Provisions The original provisions for inpatient treatment kits were established as a result of action taken on Subject 101 of Docket 132 (January 1968). That was a shipper proposal to establish a new item for expendable treatment kits or trays at class 100. Information of record indicated an average density of 9.33 pcf and an average value of $1.54 per pound (in 1968 dollars). The provisions first appeared in Supplement 18 to NMFC A-10, effective May 14, Subject 40 of Docket 725 (September 1972) was a proposal to cancel the provisions for inpatient treatment kits along with the existing entry for hospital patient kits and combine them along with maternity kits, under a new density-based item 2. The proposal was approved as modified but then subsequently appealed (Appeal 551), upheld on appeal, protested and suspended (I & S Docket No. M-27910). The ultimate decision in the investigative proceeding found that the proposed density-based classes were not shown to be just and reasonable, resulting in no change to the involved provisions. The matter was revisited under Subject 13 of Docket 756 (September 1975), a proposal to, among other things, combine and name maternity, aspirating/administration/transference and treatment kits or sets under one entry, at class 125. Once again, the proposal was approved as modified, appealed (Appeal 599), protested and suspended, with a second investigation (I & S Docket No. M-29116). As a compromise, a single density break at 5 pcf was established along with the institution of the bumping privilege, resulting in the current provisions of what is now item These amendments appeared in Supplement 9 to NMF 100-D, effective July 30, About the Involved Kits or Sets The attendant Notes governing item help define for the Classification user the nature and character of kits or sets embraced by the provisions. In this regard, Note, item 56791, governing inpatient or outpatient care or treatment kits, specifies that such kits are for use in doctors offices, hospitals, etc., and contain a mixture of three or more expendable components for the care or treatment of an individual. Some examples might include surgical sets, epidural kits and the like. Similarly, Note, item 56792, governing maternity kits, specifies that such kits consist of sanitary pads and other expendable accessories, e.g. tissues. However, it is noted that today s maternity kits may vary in their make-up or composition; 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 In a related action, Docket 726, Subject 41 (November 1972) proposed the same density scale for expendable aspirating, administration or transference kits or sets; both subjects were jointly considered in the same appeal. Subject 2, Page 3 of 6

20 % of Figures in Interval CCSB DOCKET SUBJECT 2 different kits may indeed contain different articles or accessories 3. The expendable aspirating, administration or transference kits or sets named in item are self-explanatory and generally apply on kits or sets used to facilitate delivery, drainage or transference. Typical examples would include medical catheters, as well as gastronomic, infusion or I.V. kits or sets. Transportation Characteristics Density The information of record includes 9,998 figures, exhibiting a range in density from 0.17 to pcf, for an average density of 8.62 pcf. When grouped according to the currently applicable subprovisions, the density ranges and averages are as follows: Subprovision Density Range (pcf) Density Average (pcf) Sub 1 - Less than 5 pcf 0.17 to Sub 2-5 pcf or greater 5.00 to The frequency distribution of density figures for kits or sets as shown below indicates that while the overall average density is 8.62 pcf, the greatest concentration of figures is in the 4 but less than 6 pcf interval (41.92%). Further, the density mode and median are 4.88 and 5.65 pcf, respectively. This indicates that the overall average density is not reflective of the density range, as the range is wide, and moreover, the average corresponds to neither the midpoint of the range nor the most frequently occurring density in the range. Frequency Distribution 50.00% 40.00% 30.00% 20.00% 12.98% 41.92% 23.00% 10.00% 0.00% 0.02% 0.38% 7.19% 4.84% 2.96% 2.52% 0.60% 3.58% Density Intervals (pcf) 3 While they generally contain a complement of sanitary napkins or absorbent pads, panties or briefs, some kits may also include cold packs, digital thermometers and peri bottles. Still others may contain gloves, towels, antiseptic hand wipes or sterile gauze pads. Subject 2, Page 4 of 6

21 SUBJECT 2 Handling and Stowability The involved kits or sets are packaged in inner containers in fiberboard boxes, which are generally shipped in unitized pallet loads, such as depicted below, and should not pose any significant handling problems. On selected shipments, precautionary warnings and instructions are noted, such as Do Not Double-Stack and Do Not Break Down Pallet. Care should be taken to load these products with compatible freight so as to reduce the risk of puncture or contamination especially in shipments that may contain sterile components. Liability These products are not perishable, prone to spontaneous combustion or explosion, or highly susceptible to theft, nor are they likely to damage other freight with which shipped. As mentioned, these products may be liable to damage or contamination; however, shipperprovided information indicates a limited number of claims per year, with claims ratios below 1%. There is no information available with respect to value per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for Classification provisions to reflect a commodity s known transportation characteristics. Information of record on the transportation characteristics of the involved kits or sets reveals a range in density from 0.17 to pcf, with an average of 8.62 pcf. The following table relates the information developed to the currently applicable provisions for both the current class and the class that would generally be applicable for the known average density per CCSB guidelines. Subprovision Density Range (pcf) Average Density (pcf) Current Class Class per CCSB Guidelines Sub 1 - Less than 5 pcf 0.17 to Sub 2-5 pcf or greater 5.00 to As depicted in the table, the provisions for the involved kits or sets are not in keeping with CCSB guidelines for the currently applicable classes. CCSB policy further provides that commodities or commodity groups exhibiting a wide range in density not accurately reflected by a single overall average density may be assigned density-based classes; especially where there are no unusual or significant stowability, handling or liability characteristics and where there is no other feasible means of effectively Subject 2, Page 5 of 6

22 SUBJECT 2 narrowing the range. And where densities are distributed throughout the range, commodities or commodity groups may be assigned classes predicated on a full density scale. Further, when a substantial percentage of the densities involved exceeds 20 pcf, classes based on the CCSB s standard 11-subprovision density scale which ranges from class 400 for densities of less than 1 pcf to class 60 for densities of 30 pcf or greater may be assigned. The involved kits or sets have a density range from 0.17 to pcf. The densities are distributed throughout the range with 4.67% of the figures exceeding 20 pcf. This indicates that the standard 11-subprovision density scale 4 would reflect the densities of the involved kits or sets as opposed to the current single density break at 5 pcf, and would be consistent with CCSB policy and precedent. Since 2000, when the classification policies with respect to full-scale density-based provisions were changed to include the policy regarding the extended, 11-subprovision density scale, many items in the NMFC have been amended or established to provide that extended scale. For instance, as a result of action taken on Docket , Subject 8 (May 2012), which was a consolidation and updating of insulation or insulating material entries, item was amended to provide the extended full density scale. The commodities were shown to have a density range from 0.06 to pcf, for an average of 7.97 pcf, with the densities distributed throughout the full density array and a substantial percentage of densities exceeding 20 pcf. There were no unusual or significant stowability, handling or liability characteristics associated with the products. The changes first appeared in Supplement 2 to NMF 100-AL and became effective July 21, CCSB policies also call for replacing outdated terminology and eliminating excess or unclear wording so as to foster clarification and simplification. In this respect, the provisions covering maternity kits are not necessarily reflective or inclusive of all kits currently moving in commerce. The information developed indicates that components may vary and contain different articles (and not those specified in the attendant Note, item 56792) depending on the individual kit. Therefore, amending the attendant Note with language that reflects the varied content of maternity kits would be consistent with CCSB policy. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 4 The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 2, Page 6 of 6

23 SUBJECT 3 Re: Hand Tools, other than power Staff Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class TOOLS, OR PARTS NAMED: subject to item Tools, NOI, other than plastic, in boxes, drums, or in Packages 1241 or Tools, hand, forged, NOI, see Note, item , viz.: Adzes; Bars, claw or wrecking, or Crowbars; Bars, tamping or digging; Blacksmiths Anvil Tools, viz.: Chisels, counter-sink; Cutters, cold or hot; Flatters; Fullers; Hammers, set; Hardies; Headers; Punches; Swages; Tongs; Hammers, hand, with 4 pound or heavier head; Hoes, grub, hazel or accomac; Mattocks; Mauls; Picks; Railway Track Maintenance Tools, viz.: Chisels, track; Forks, rail; Nippers, tie; Pullers, spike; Punches, track tie; Tongs, tie; Wrenches, track; Sledges; Wedges; Without handles, or with attached handles, in packages Subject 3, Page 1 of 7

24 SUBJECT 3 Present Classification Provisions Continued Item Description Class Tools, hand, other than power, other than plastic, see Notes, items and , viz.: Awls; Bevels; Bits, auger or drill, NOI; Boxes, miter; Braces; Chisels; Clamps or Screws, bench or hand; Clippers or Cutters, bolt; Compressors, piston ring; Countersinks; Drills, NOI, including Star Drills; Expanders; Extractors, pipe or screw; Files or Rasps; Gauges, carpenter; Gauges, railway track; Grinders, valve; Hammers, hand, NOI, with or without handles; Holders, tool; Irons, caulking or yarning; Levels, including carpenters or railway track; Planes; Pliers; Points, bull or moil; Pullers, gear and wheel terminal, or Parts; Pullers, nail; Punches, other than spring type; Saws, hand, NOI; Scrapers, carbon; Scrapers, metal, including Floor and Pipeline Scrapers, Smoothers or Surfacers, with or without handles, handles may protrude; Screwdrivers; Sets, nail; Sets, saw, or Parts; Shaves, spoke; Shears or Snips, tinners ; Squares; Tools, bending or flaring, including Benders, rail; Tools, body and fender, including Dollies and Spoons; Tools, brake; Tools, hand, NOI; Tools, pipe, including Cutters, Dies, Reamers, Stocks, Threaders or Tongs; Subject 3, Page 2 of 7

25 SUBJECT 3 Present Classification Provisions Concluded Item Description Class Tools, hand, other than power, other than plastic: subject to item Tools, tire changing, NOI; Wrenches, NOI, including Adjustable Wrenches, Pipe Wrenches, or Socket Wrench Sets; In packages NOTE Will also apply on tools packed in tool boxes, cabinets or chests enclosed in boxes or crates, provided the tools comprise not less than 30 percent of the gross package weight NOTE Provisions do not apply on toy tools. Toy tools are classified under item Proposed Classification Provisions Item Description Class TOOLS, OR PARTS NAMED: subject to item A-NEW Tools, NOI, hand, other than power, see Notes, items B-NEW and C-NEW, in boxes, 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 B-NEW NOTE Also applies on tools packed in tool boxes, cabinets or chests enclosed in boxes or crates. C-NEW NOTE Does not apply on toy tools. For applicable provisions, see item 84260, Games or Toys, NOI Tools, NOI, other than hand, other than plastic, in boxes or Packages 1241 or Tools, hand, forged, NOI, etc... Cancel; see item A-NEW Tools, hand, other than power, other than plastic, etc... Cancel; see item A-NEW NOTE Cancel; see item B-NEW NOTE Cancel; see item C-NEW. Subject 3, Page 3 of 7

26 SUBJECT 3 Analysis Research Project 1134 This proposal is based on information developed through Research Project 1134 involving hand tools, other than power. The project was initiated in July 2011 in response to indications of transportation characteristics inconsistent with CCSB guidelines for the currently applicable classes. As part of the research, 391 potential manufacturers or shippers and six trade associations were contacted in December 2011, and for those that did not respond, again in March 2012, inviting them to participate. From this sampling, 48 of the manufacturer/shipper surveys were returned as undeliverable, 16 companies responded that they did not manufacture or ship the involved articles, and 23 companies provided at least some information. Not all of the information was usable, however, and one of the responding companies requested removal from the mailing list. With respect to the associations, two responded that they did not represent manufacturers or shippers of the involved articles, and there was no response from the other four. History of Provisions The provisions of item for forged hand tools were established as a result of action taken on Docket 123, Subject 149 (March-April 1966), and first appeared in Supplement 11 to NMFC A-9, effective July 20, The provisions of item for hand tools, other than power, were established as a result of action taken on Docket 58, Subject 90 (April 1953), and first appeared in Supplement 16 to NMFC A-1, effective October 15, Both items have remained substantially unchanged since their establishment. About Hand Tools Items and apply on various types of hand tools that are not poweroperated. Item applies on certain forged hand tools, while item embraces hand tools that are not named elsewhere in the Classification. Both provisions exclude toy tools and direct the Classification user to item 84260, which names Games or Toys, NOI. Examples of tools embraced within items and are shown below and on the following page. Forged Hand Tools Subject 3, Page 4 of 7

27 % of Figures in Interval CCSB DOCKET SUBJECT 3 Hand Tools Transportation Characteristics Density The information of record encompasses 29,622 density observations from a variety of sources, including shipper- and carrier-supplied data, CCSB dock surveys, and the CCSB s Density Study 1. The densities range from 0.32 to pcf, with a simple average density of pcf. When evaluated by item, hand tools reported to be moving under item were found to range in density from 0.32 to pcf, with an average density of pcf, while hand tools reported to be moving under item were found to range from 1.04 to pcf, with an average density of pcf. A frequency distribution of the overall density range is provided below. Frequency Distribution 30% 28% 25% 20% 15% 10% 6% 12% 12% 12% 14% 7% 9% 5% 0% 0% 0% 0% Density Intervals (pcf) 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 TM item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. Subject 3, Page 5 of 7

28 SUBJECT 3 As shown in the distribution, the density figures are distributed throughout the range, and approximately 19% of the figures exceed 20 pcf. Handling The information of record indicates that the involved hand tools are generally tendered for shipment in fiberboard boxes of regular size and shape that may be palletized. No unusual or significant negative handling considerations have been identified. Stowability As with handling, no unusual or significant negative stowability considerations are noted. The packages will generally provide a flat load-bearing surface for other freight and should not present any difficulties when structuring a load. Liability There is no indication of any unusual or significant liability considerations. None of the responding manufacturers or shippers provided any information on the value of these articles; however, there is also no evidence of a claims problem. Relationship to CCSB Policies and Guidelines CCSB policy regarding clarification, simplification and uniformity calls for combining descriptions embracing related commodities, eliminating excess or unclear wording, employing language that is concise and clear as to intent, structuring commodity descriptions so as to foster clarification and simplification, and listing items under appropriate generic headings. In keeping with these policies, this proposal would cancel the provisions of items and with reference to a new item under the Tools, or Parts Named generic heading for Tools, NOI, hand, other than power. Concurrently, Notes, items and would be canceled and reestablished in the interest of clarification. In addition, item , applying on Tools, NOI, other than plastic, would be amended by the addition of the restriction, other than hand, to avoid a potential interpretation conflict with the proposed new item, and by removal of the superfluous packaging reference, in drums. CCSB policy also calls for provisions to reflect a commodity s known transportation characteristics. Information of record indicates that hand tools moving under the provisions of items and range in density from 0.32 to pcf, with a simple average density of pcf, and no unusual or significant negative handling, stowability or liability considerations. When evaluated on the basis of the reportedly applicable item, hand tools moving under the provisions of item range in density from 0.32 to pcf, with an average density of pcf. CCSB guidelines for the currently applicable class 60 call for a minimum average density of 30 pcf. Hand tools reported to be moving under the provisions of item range in density from 1.04 to pcf, with an average density of pcf. CCSB guidelines for the currently applicable class 70 call for a minimum average density of 15 pcf. CCSB policy further provides that commodities exhibiting a wide density range not accurately reflected by a single overall average density may be assigned density-based classes; especially where there are no unusual or significant stowability, handling or liability characteristics and where there is no other feasible means of effectively narrowing the range. And where densities are distributed throughout the range, commodities may be assigned classes predicated on a full density scale. In this regard, CCSB policy provides that when a substantial percentage of the densities involved exceed 20 pcf, the density scale should Subject 3, Page 6 of 7

29 SUBJECT 3 incorporate the alternative standard progression of 11 subprovisions that ranges from class 400 for densities of less than 1 pcf to class 60 for densities of 30 pcf or greater. Canceling the provisions of items and with reference to a new item for hand tools, NOI, other than power, which assigns the CCSB s standard 11-subprovision density scale 2, is consistent with the aforementioned policies. It is also consistent with precedent established by the Surface Transportation Board, which has stated that density is usually the most important transportation characteristic, and that density-based classes are desirable for products which pose no significant stowability or handling problems and where there are wide variations in density. There is also considerable CCSB precedent in support of this proposal. A recent example may be found in Docket , Subject 4 (January 2012), which was a proposal to cancel various individual items for sinks or lavatories with reference to item for Plumbers Goods, which assigns the standard 11-subprovision density progression, while concurrently amending item to name sinks and lavatories. Based on the information of record, this proposal is in keeping with CCSB policy and precedent. 2 The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 3, Page 7 of 7

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31 SUBJECT 4 Re: Burners, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven Staff Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Burners, NOI, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven: Sub 1 Motor operated, in boxes, crates or drums Sub 2 Other than motor operated, oil, in boxes, crates or drums Sub 3 Other than motor operated, gas, in packages Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Burners, NOI, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven: Sub 1 In boxes or crates, or in fiberboard containers securely fastened to lift truck skids or pallets, 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 as set forth in sub 1, 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 Analysis Research Project 1147 Research Project 1147 was initiated in December 2011 to investigate the transportation characteristics of articles moving under the provisions of item , Burners, NOI, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven. The complete description is found herein under the Present Classification Provisions. During the course of Project 1147, questionnaires were mailed to 147 potential manufacturers or shippers and nine trade associations in March of 2012, and again to those that did not respond, in June of 2012, inviting them to participate in the research. From this sampling, one survey was returned as undeliverable, three companies responded that they did not ship the involved articles, and Subject 4, Page 1 of 5

32 SUBJECT 4 nine companies provided at least some information. One additional company was identified subsequent to the mailings and they have been added to the Notification List for this proposal. Regarding the nine trade associations contacted, three responded that they did not represent shippers of the involved articles. No response was received from the remaining associations. History of Provisions The basic provisions of item were adopted from the rails in With the exception of packaging changes, the current provisions were established as a result of action taken on Docket 131, Subject 28 (November 1967). That was a proposal to, among other things, amend item to include a reference to burners, sprayers or vaporizers for commercial or industrial baking ovens. The proposal was approved as modified, and the changes first appeared in Supplement 13 to NMFC A-10, effective March 12, About Burners, Sprayers or Vaporizers Item applies on burners, sprayers or vaporizers for boilers, furnaces or commercial or industrial baking ovens. They are used to control a fuel source to promote efficient combustion and reduce emissions. Among the most common fuels are natural gas, propane and oil. While item references sprayers and vaporizers to further describe these articles, they are commonly referred to as burners. Examples of different types of burners are shown below. Boiler Burners Furnace Burners Commercial or Industrial Oven Burners Subject 4, Page 2 of 5

33 % of Figures in Interval CCSB DOCKET SUBJECT 4 Transportation Characteristics Density The information of record includes 4,580 density observations submitted by shippers and carriers, obtained through CCSB dock surveys and culled from the CCSB s Density Study 1. The observations range from 1.43 to pcf, with a simple average density of pcf. A frequency distribution of the overall density range is provided below. Frequency Distribution 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% 0% 0% 3% 12% 15% 15% 16% 15% 16% 4% 4% Density Intervals (pcf) As depicted in the frequency distribution, while the figures are distributed throughout the range, they are clustered fairly evenly within the three proposed density groups, with 30% less than 8 pcf, 31% between 8 and 12 pcf, and 39% 12 pcf or greater. The table below provides an overview of the density observations as they relate to the proposed density groups. Proposed Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater A review of the density observations also reveals that there is essentially no difference in density based on the currently applicable subprovisions, which are predicated on whether or 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 TM 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 3 of 5

34 SUBJECT 4 not the burner is motor-operated, and if not motor-operated, the type of fuel burned. This is illustrated in the table below. Reportedly Applicable Subprovision Density Range (pcf) Average Density (pcf) Sub Sub Sub Handling Information of record indicates that the involved burners are tendered for shipment in boxes or crates, in fiberboard containers securely fastened to lift truck skids or pallets, or attached to lift truck skids or pallets. Generally, articles so tendered will not present any unusual or significant negative handling considerations. It is noted, however, that in an extremely limited number of instances (nine out of the 4,580 observations of record or 0.20%) the length of the handling unit may exceed 96 inches due to the size of the burner. In such rare instances, handling the involved burner may be more difficult. Stowability When tendered in a box or crate, or in a fiberboard container securely fastened to a lift truck skid or pallet, a flat load-bearing surface will be present for loading other freight on top, and there will be lateral support for adjacent freight, resulting in a greater ability to readily structure a load and enabling better utilization of available vehicle space. When the involved burners are tendered secured on lift truck skids or pallets, but not in a box, crate or fiberboard container, they may pose some negative stowability considerations. Specifically, burners tendered in this manner will generally lack a flat load-bearing surface for the loading of other freight on top of the article, and they may not provide lateral support for freight loaded adjacent to them in the vehicle. They may also have protrusions and exposed surfaces or edges that can limit the type of freight that may be safely stowed around them. In the LTL environment, this means that carriers will either not be able to load other freight on top of or adjacent to the unit, or that they will have to employ the use of load decks and/or dunnage, resulting in an increase in time to properly structure the load. Liability The involved articles are not perishable, prone to spontaneous combustion or explosion, nor susceptible to theft. As is the case with most general commodities, when tendered for shipment fully enclosed within a box or crate, or in a fiberboard container secured to a lift truck skid or pallet, they should not be unusually susceptible to damage, nor likely to damage other freight with which transported. When tendered on a lift truck skid or pallet without protective packaging, however, these products may exhibit a greater susceptibility to damage compared to similar units tendered in a box, crate or fiberboard container. Burners shipped with little or no protective packaging may have exposed edges or protrusions that can puncture, mar or otherwise damage adjacent freight. Additionally, shipments loaded in a vehicle are generally supported to some extent by adjacent freight. When these articles are not in a box, crate or fiberboard container, they may not provide sufficient lateral support for adjacent freight. This can result in damage to either the article itself or the adjacent freight. Information on value is extremely limited, with only one reported figure of $11.36 per pound, and there is no information available with respect to claims. Subject 4, Page 4 of 5

35 SUBJECT 4 Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record shows densities for the involved articles to range from 1.43 to pcf, with a simple average density of pcf. CCSB policy provides that where commodities or commodity groups exhibit a wide density range not accurately reflected by a single, overall average density, they may be assigned density-based classes. However, in this instance some negative stowability and liability considerations have been identified that must also be considered, in accordance with CCSB policies. These have been detailed in the analysis and include such factors as the lack of a flat load-bearing surface for top freight and the lack of lateral support for adjacent freight when the burner is not tendered fully enclosed within a box, crate or fiberboard container. In addition, those burners that are not tendered in boxes, crates or fiberboard containers offer less protection against damage to the burner itself and to other freight with which it is shipped. The following table relates the information of record to the proposed density groupings and CCSB guidelines for the proposed classes for burners tendered in boxes or crates, or in fiberboard containers securely fastened to lift truck skids or pallets. Density Group (pcf) Density Range (pcf) Average Density (pcf) Proposed Class CCSB Density Guideline (pcf) Less than but less than or greater With respect to commodities that exhibit significant less-than-favorable stowability or liability characteristics, classification precedent has been to assign a class higher than what would generally be called for under the density guidelines. Based on the information of record, this proposal would establish classes one class higher than that called for under CCSB density guidelines for the involved articles when tendered in packages other than boxes or crates, or fiberboard containers securely fastened to lift truck skids or pallets. Such an approach provides a means of addressing the varying stowing and liability characteristics associated with these articles, while also providing a method for narrowing the identified wide density range 2. A similar approach was used with respect to the provisions of item , for iron or steel tanks. As detailed in the record of Subject 5 of Docket (June 2010), the classes assigned for each density group reflected a one or two class increase over the class generally called for under the density guidelines. The proposal was approved as modified, and those provisions first appeared in Supplement 2 to NMF 100-AJ, effective August 28, In view of the information of record, it would be in keeping with CCSB policy and precedent to establish provisions based on packaging and density, as proposed. 2 Both sets of classes would include reference to Item (Rule) 170, the inadvertence clause. Subject 4, Page 5 of 5

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37 SUBJECT 5 Re: Washers (Washing Machines) or Washer-extractors, laundry, other than household Staff Contact: Donald A. Newell Telephone (703) newell@nmfta.org Allison L. Austin (703) austin@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Steam, Commercial or Institutional Type, other than household: subject to item Washer-extractors, in boxes, crates or Package Washers (Washing Machines), power, in boxes, crates or Package Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Steam, Commercial or Institutional Type, other than household: subject to item Washer-extractors, etc.... Cancel; see item Washers (Washing Machines) or Washer-extractors: Sub 1 In boxes, crates or Packages 1022 or 2426, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 10 but less than Sub 4 15 or greater Sub 5 In packages other than boxes, crates or Packages 1022 or 2426, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 10 but less than Sub 8 15 or greater Analysis Research Project 1110 This proposal is based on information developed through Research Project 1110, which was initiated by the CCSB in November 2009 in response to interpretation inquiries regarding Subject 5, Page 1 of 7

38 SUBJECT 5 whether particular products are classified under the provisions of item as washerextractors or item as washers (washing machines). In opinions, determinations of the applicable provisions have generally yielded to shipper representation of the products. During the course of the project, 120 potential manufacturers or shippers of washers or washer-extractors, and five associations believed to represent those companies, were sent questionnaires in March, and for those that did not respond, again in May of Of those contacted, 11 companies responded that they do not manufacture or ship these articles, one indicated that they do not ship via less-than-truckload (LTL) motor carrier service, and seven companies provided at least some information; however, not all the information was usable. In addition, two associations responded that they do not represent manufacturers or shippers involved with these commodities. No other associations responded to our request. Additional information of record was developed through CCSB dock surveys, including a visit to a major manufacturer of the products, carrier-submitted Shipment Information Forms and the CCSB s Density Study 1. History of Provisions Item , applying on washer-extractors, was established as a result of action taken on Subject 18 of Docket 101 (November 1961). Information provided by the shipper proponent showed a range in density from to pcf. While the densities warranted class 77.5, the proponent proposed class 85 in light of negative stowability considerations. That proposal was approved as modified, and the provisions first appeared in Supplement 3 to NMFC A-6, effective March 22, They have remained substantially unchanged to the present. The provisions of item for washers (washing machines) were adopted from the rails in The current class 92.5 was 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. About Washers or Washer-Extractors The washer-extractor was introduced to provide the additional step of extracting excess water from the wet fabrics through a spin cycle. Over time, products marketed as washers, which previously did not extract water, also became equipped with this function, generating ambiguity in the NMFC provisions. Based on information developed through the course of research, there appears to be no industry standard delineating the difference between a washer and washer-extractor. These articles are used in a range of commercial and institutional settings, including in laundromats, hotels and correctional facilities. As shown in the examples on the following page, the size, shape and specifications of the washers or washer-extractors vary, depending upon the needs of the facility. 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 5, Page 2 of 7

39 SUBJECT 5 Shipments of Washers or Washer-Extractors Washers or washer-extractors may be tendered in crates, in boxes (which may or may not be palletized), or secured on lift truck skids or pallets. Those tendered on lift truck skids or pallets may be simply wrapped in plastic film or they may be wrapped in plastic film and have packing forms such as corner posts, and top and side fiberboard panels. Subject 5, Page 3 of 7

40 % of Figures in Interval CCSB DOCKET SUBJECT 5 Transportation Characteristics Density Overall, the information of record for washers or washer-extractors includes 2,450 density observations. The products range in density from 2.18 to pcf, with a simple average density of pcf. The frequency distribution shown below illustrates that the densities are distributed throughout the range. However, the data can be divided into three density groupings of less than 10 pcf, 10 but less than 15 pcf, and 15 pcf or greater. Frequency Distribution 30.00% 28.16% 25.00% 21.63% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 0.00% 1.51% 5.22% 10.00% 15.06% 12.33% 4.33% 1.76% Density Intervals (pcf) When evaluated on the basis of the three density groupings, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Percentage of Figures in Group Less than % 10 but less than % 15 or greater % Handling When tendered in crates, or on lift truck skids or pallets, washers or washerextractors will generally exhibit handling characteristics similar to those of other like-packaged freight. These packages may include handling instructions such as Forklift From One Side Only and This End Up. It should be noted that while the majority of shipments appear to be tendered on lift truck skids or pallets, some boxes are not tendered on lift truck skids or pallets and have specific pictorial markings instructing the carrier Do Not Forklift. This freight may require the Subject 5, Page 4 of 7

41 SUBJECT 5 use of manual handling equipment, but these units are generally lighter and smaller in size, and there is no evidence to suggest that it presents a significant handling issue. Stowability Washers or washer-extractors tendered in boxes or crates typically do not present any stowability concerns. However, in roughly 50% of the observations where packaging is known, washers or washerextractors are tendered in packages other than boxes or crates. This includes those on lift truck skids or pallets that are wrapped in plastic film, as shown in the photograph on the right, or that may be wrapped in plastic film and have protective packing forms. When tendered in packages other than boxes or crates, some negative stowability considerations have been identified. These washers or washer-extractors may lack a regular load-bearing surface for top freight. When tendered this way, pictorial markings often indicate Do Not Stack. Also, when placing the washer or washer-extractor inside the carrier s vehicle, such packaging may limit the type of freight that can be safely stowed adjacent to it. This can result in increased time on the part of the carrier to properly structure the load, including the use of dunnage, to minimize the potential for damage. Liability Washers or washer-extractors are not perishable, susceptible to theft or given to spontaneous combustion or explosion. When tendered in boxes or crates, washers or washerextractors will generally be afforded more protection against damage than when not so packaged. When tendered in packages other than boxes or crates, washers or washer-extractors may be more susceptible to damage. These packages may provide minimal protection for the product, creating the potential for damage. Due to the large size of many of these articles, any protrusions could lead to potential damage to other freight. However, no carriers have reported a claims issue, and shippers have reported five or fewer claims per year. Limited value information shows a range from $4.26 to $16.84 per pound, with an average value of $10.09 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for amending provisions that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. The ambiguity between a washer and washer-extractor has resulted in confusion over the applicable provisions for commercial washing equipment. Opinion varies within the industry regarding the difference between a washer and a washer-extractor; thus, there is no definitive differentiation that can be applied within the NMFC regarding these products. As such, in the interest of clarification and simplification, it would be within CCSB policy to combine these descriptions embracing related commodities. Under this proposal, the provisions of item for washer-extractors would be canceled with reference to item Concurrently, the description of item would be amended to include the noun Washer-extractors. Information of record shows washers or washer-extractors range in density from 2.18 to pcf, with an average density of pcf. CCSB policy states that when commodities Subject 5, Page 5 of 7

42 SUBJECT 5 exhibit a wide density range, density-based classes may be established. As shown in the table below, the data can be divided into three density groupings of less than 10 pcf, 10 but less than 15 pcf, and 15 pcf or greater, with classes reflective of the average density of each respective grouping. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines CCSB Density Guideline (pcf) Less than but less than or greater However, CCSB policies also state that unusual or significant negative handling, stowability or liability characteristics may warrant deviation from the density guidelines. When washers or washer-extractors are tendered in boxes or crates, negative handling, stowing or liability considerations are greatly mitigated. Most boxes or crates provide a flat load-bearing surface and allow the carrier to safely load freight adjacent to them. Articles tendered in boxes or crates also typically provide greater protection against damage to the article itself and to other freight. Negative stowing and liability concerns have been found when washers or washerextractors are tendered for shipment in packages other than boxes or crates. Where packaging is known, these forms of shipment represent nearly half of all observations. These packages generally do not provide a flat load-bearing surface, and may require additional attention, as prescribed by pictorial instructions on the package. They may impede the carrier s ability to safely load adjacent freight and may be more susceptible to damage or likely to damage other freight during transit. Based on the identified stowing and liability concerns, classification precedent has been to assign a class higher than that provided by the CCSB density guidelines. This proposal would establish classes based on packaging and density 2, with a one-class adjustment for those washers or washer-extractors in packages other than boxes, crates or Packages 1022 or 2426 (which are box-type packages), as shown in the table below. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines One-Class Adjustment for Packaging Less than but less than or greater A similar approach was taken on Subject 1 of Docket (June 2009) involving item , for air compressors. Density was determined to be the primary transportation characteristic when air compressors were shipped in boxes or crates. When tendered in other packages, the air compressors were not as well protected as when in boxes or crates and thus 2 Both sets of classes would include reference to Item (Rule) 170, the inadvertence clause. Subject 5, Page 6 of 7

43 SUBJECT 5 presented additional stowing and liability concerns. Accordingly, classes were predicated on packaging and density, assigning one class higher for air compressors tendered for shipment in packages other than boxes or crates. That proposal was approved as docketed, and the provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 5, Page 7 of 7

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45 SUBJECT 6 Re: Doors or Door Sections or Grilles, garage or commercial or industrial building Staff Contact: Nathan D. Ripke Telephone (703) ripke@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Doors or Door Sections, garage or industrial building, overhead, plastic and aluminum, KD flat, with door track packed in same box Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding, rolling or curtain type, NOI, iron or steel, see Note, item 34282, in packages: Sub 1 Greatest dimension 96 inches or more Sub 2 Greatest dimension less than 96 inches NOTE Also applies on accompanying hardware, angles, bars, castings, chain, cable, guides, hoods, pipe, rollers, springs, motors, sprockets, track, hinges, sheaves, brackets, handles, locks, hangers, rails, hooks, pulleys, rods or other fittings when in same package with the doors, door sections, grilles, partitions or shutters, or, when in shipments of 36,000 pounds or more, separate packages Doors, farm, garage, industrial or utility building, overhead, iron or steel, without covering or skin, see Note, item 34311, with or without door track, installation hardware or operating mechanism, in packages NOTE Applies on assembled door framework equipped with hinges and reinforcing trusses but without covering or skin Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding or rolling type, aluminum and iron or steel combined, or aluminum and iron or steel and wood combined, see Note, item Doors or Door Sections, garage or industrial building, overhead or sliding, wooden, with or without hardware applied, in packages, see Note, item Subject 6, Page 1 of 8

46 SUBJECT 6 Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Doors or Door Sections, garage or industrial building, overhead, plastic and aluminum, etc... Cancel; see item A-NEW Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding, rolling or curtain type, NOI, iron or steel, etc... Cancel; see item A-NEW NOTE No Change Doors, farm, garage, industrial or utility building, overhead, iron or steel, without covering or skin, etc... Cancel; see item A-NEW NOTE Cancel; no further application Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding or rolling type, aluminum and iron or steel combined, or aluminum and iron or steel and wood combined, etc... Cancel; see item A-NEW Doors or Door Sections, garage or industrial building, overhead or sliding, wooden, etc... Cancel; see item A-NEW A-NEW Doors or Door Sections or Grilles, garage or commercial or industrial building, overhead, sliding, rolling or curtain type, NOI, in packages, see Notes, items B-NEW and C-NEW B-NEW NOTE Also applies on accompanying hardware and fittings when shipped in the same package. C-NEW NOTE Doors or door sections or grilles tendered for shipment on lift truck skids or pallets must be securely fastened to and must not overhang the edges of the lift truck skid or pallet deck. Exposed surfaces and edges must be completely wrapped with plastic film or corrugated fiberboard or protected by wood or similar material. Subject 6, Page 2 of 8

47 SUBJECT 6 Analysis Research Project 1163 Research Project 1163 on doors or door sections, garage or commercial or industrial building, overhead, sliding, rolling or curtain type was initiated in May 2012 to review the five items within the Classification that apply on these commodities and to determine their transportation characteristics. Hereinafter, these products will be referred to as doors, door sections or grilles. A total of 156 potential manufacturers or shippers of doors, door sections or grilles, and six associations believed to represent those companies, were sent questionnaires in June and August of Of the companies contacted, one responded that they do not manufacture or ship doors, door sections or grilles, eight questionnaires were returned as undeliverable, and 13 companies provided information; however, not all the information was usable. One association responded that they do not represent the involved companies, while no response was received from the remaining five associations. Additional information was obtained through CCSB dock surveys, carrier-submitted Shipment Information Forms and the CCSB Density Study 1. History of Provisions The current provisions for the involved doors, door sections or grilles are found in five different items, which are based on material consist and/or type. The current provisions of item are the result of action taken on Docket 91, Subject 77 (November 1959). Information on that record revealed densities ranging from 7.31 to 9.27 pcf, and a value per pound of $0.75 (in 1959 dollars). No average density or significant handling, stowability or liability concerns were reported. Approved as modified, those provisions were assigned a class 92.5 and first appeared in Supplement 1 to NMFC A-5, effective September 29, The current provisions of item are the result of action taken on Docket , Subject 10 (August 2005). Information on that record showed densities ranging from to pcf, with an average density of pcf for handling units less than 96 inches in greatest dimension, and a range from 4.28 to pcf, with an average density of pcf for handling units of 96 inches or more in greatest dimension. Value per pound ranged from $1.07 to $10.00, with an average of $2.92 (in 2005 dollars). That proposal was approved as docketed and assigned a class 70 when greatest dimension is less than 96 inches, and a class 85 when greatest dimension is 96 inches or more. The class 85 was based on a one-class increase from the guideline class of 77.5 generally associated with an average density of pcf to account for extra handling and stowability considerations presented by the extended length 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 3 of 8

48 SUBJECT 6 of the involved commodities. Those provisions first appeared in Supplement 5 to NMF 100-AE, effective October 29, Item and attendant Note, item were established as a result of action taken on Docket 893, Subject 9 (May 1989) to provide specific provisions reflective of the transportation characteristics of farm, garage, industrial or utility building overhead doors, constructed of iron or steel, without covering or skin. Information on that record revealed densities ranging from 1.65 to 4.00 pcf, with an average density of 2.55 pcf. Those commodities were also reported to have negative handling and stowability characteristics. Approved as docketed, the provisions of item were assigned a class 300 and first appeared, with Note, item 34311, in Supplement 2 to NMF 100-P, effective June 24, The current provisions of item are the result of action taken on Docket 46, Subject 29 (June 1950), which added or Grilles to the commodity description with no class change. Those provisions first appeared in Supplement 14 to NMFC No. 10, effective November 7, Item was established as the result of action taken on Docket 38, Subject 12 (October 1948) to remain competitive with the rails. The item first appeared in Supplement 6 to NMFC No. 10, effective March 14, About Garage or Commercial or Industrial Building Doors, Door Sections or Grilles The involved products are identified as doors, door sections or grilles for garages, or commercial or industrial buildings. These commodities are composed of various materials, including steel, aluminum, wood, plastic or a combination of any of the aforementioned. The doors, door sections or grilles also vary in type, including: overhead, sliding, rolling or curtain functionality. Given their intended use to enclose, secure or protect an open area where vehicles or groups of people may pass through, these commodities can exceed 27 feet in length. Examples of these products are shown below. Subject 6, Page 4 of 8

49 % of Figures in Interval CCSB DOCKET SUBJECT 6 Transportation Characteristics Density Information of record includes 269 density figures ranging from 1.12 to pcf, with an average of 8.96 pcf. The frequency distribution below shows that the greatest concentration of figures is in the 8 but less than 10 pcf density interval. Frequency Distribution 25% 20% 15% 10% 5% 0% 0% 4% 6% 14% 20% 23% 14% 10% 6% 1% 1% Density Intervals (pcf) As discussed below, the involved doors, door sections or grilles vary greatly in length/size. When the data is evaluated based on greatest dimension 2, as shipped, the following density ranges and averages are found. It should be noted that the ranges overlap, and as the greatest dimension increases, the average density also increases. Density Range (pcf) Average Density (pcf) Greatest dimension exceeding 192 inches Greatest dimension exceeding 96 inches but not exceeding 192 inches Greatest dimension not exceeding 96 inches Handling The doors, door sections or grilles vary greatly in size, with reported lengths up to 27 feet (or 324 inches) or more, and an average length of approximately 14 feet. As the length/size increases, the handling into and out of the vehicle becomes considerably more difficult, and specialized equipment, or additional personnel, may be necessary to safely handle longer units. Furthermore, as the length increases, cross-dock operations can be 2 Item (Rule) 568, Heavy or Bulky Freight Loading or Unloading, uses 8 feet (or 96 inches) in greatest dimension as the threshold measurement at which freight becomes more difficult to load and unload when compared to general boxed freight. Subject 6, Page 5 of 8

50 SUBJECT 6 significantly affected. Often there is not enough room at carrier facilities to safely or easily handle and maneuver excessively long doors, door sections or grilles. When a handling unit exceeds 96 inches, even palletized or crated shipments can be difficult to safely handle with mechanical equipment. The level of difficulty increases as the length of the article increases, even if fork extensions are available for use. Ninety-three percent of the observations on this record exceed 96 inches in length. Examples of those shipments are shown below. Stowability Doors, door sections or grilles are tendered in a variety of packages and configurations secured on lift truck skids or pallets, or in crates. The skids or pallets are generally built long enough to support the entire door, door section or grille, but sometimes the freight may overhang the skid or pallet. Handling units not exceeding 96 inches in greatest dimension generally do not pose any unusual or significant stowing problems. However, when handling units of doors, door sections or grilles exceed 96 inches in greatest dimension additional stowing concerns are presented. Furthermore, shipments exceeding 192 inches are even more difficult to stow. Subject 6, Page 6 of 8

51 SUBJECT 6 While doors, door sections or grilles may be shipped in packages that provide a flat load-bearing surface, many shippers instruct carriers to Do Not Double Stack or Do Not Top Load freight. This limits the carrier s ability to structure a load on and around larger doors, door sections or grilles. Liability Doors, door sections or grilles are not perishable, prone to spontaneous combustion or explosion, or susceptible to theft. The involved commodities do not have the propensity to damage freight with which transported nor are they unusually likely to be damaged in transit. A limited amount of information on value indicates a range from $0.27 to $11.11 per pound, with an average value of $2.71 per pound. Shippers reported six or fewer claims annually, while one carrier reported a claims ratio of 0.53% on shipments currently moving under item and 0.10% for shipments currently moving under item Relationship to CCSB Policies and Guidelines CCSB policies state that classifications should reflect a commodity s known transportation characteristics. The information of record includes 269 density observations, which range from 1.12 to pcf, with an average of 8.96 pcf. Under CCSB guidelines, an average density of 8.96 pcf is generally associated with a class 110, absent any negative handling, stowing or liability considerations. However, as discussed throughout the analysis, doors, door sections or grilles exhibit significant handling and stowability concerns. Specifically, it was found that greatest dimension has the most considerable effect on the transportability of these products, and as the greatest dimension increases the handling and stowing issues increase exponentially. The table below displays the resulting average densities, classes based on CCSB density guidelines and the proposed class when the data is evaluated based on greatest dimension (in eight-foot increments). It should be noted that 93% of the observations of record were found to have a greatest dimension exceeding 96 inches (8 feet). Average Density (pcf) Class Based on CCSB Density Guidelines Proposed Class Greatest dimension exceeding 192 inches Greatest dimension exceeding 96 inches but not exceeding 192 inches Greatest dimension not exceeding 96 inches As shown in the table above, as the greatest dimension increases making the articles more difficult to handle and stow the average density also increases. The proposed class 125 for handling units with a greatest dimension exceeding 192 inches represents a two-class increase from the CCSB guideline class 100 generally associated with an average density of pcf. The proposed class 125 for handling units with a greatest dimension exceeding 96 inches but not exceeding 192 inches represents a one-class increase from the CCSB guideline Subject 6, Page 7 of 8

52 SUBJECT 6 class 110 generally associated with an average density of 8.44 pcf. When handling units do not exceed 96 inches in greatest dimension, no significant handling, stowing or liability concerns have been identified, making density the primary transportation characteristic. Under CCSB guidelines, an average density of 7.40 pcf is associated with the proposed class 125. CCSB policy regarding clarification, simplification and uniformity calls, in part, for combining item descriptions embracing related commodities, structuring item descriptions so as to foster clarification and simplification, and providing uniformity in provisions addressing the same or similar circumstances. Therefore, it would be in keeping with CCSB policy, as proposed, to cancel the current individual classifications for doors, door sections or grilles with reference to a new item applying on overhead, sliding, rolling or curtain-type garage, commercial or industrial doors, door sections or grilles, NOI, at class 125. Combining the classifications into a single item would mitigate, if not solve, any interpretation disputes. Furthermore, two new Notes would be added and referenced by the new item. The first Note would clarify that the provisions also apply on accompanying hardware and fittings when shipped in the same package. The second would provide additional packaging requirements for the involved commodities when tendered on lift truck skids or pallets by specifying the doors, door sections or grilles must be securely fastened to, and must not overhang the edges of, the lift truck skid or pallet, and they must have exposed surfaces and edges completely wrapped with plastic film or corrugated fiberboard or be protected by wood or similar material. This proposal is also in keeping with classification precedent. As a result of action taken on Docket , Subject 4 (May 2012) nine different classifications for brass, bronze or copper pipe, tubing, or pipe or tubing fittings with provisions based on exact material consist and/or type were canceled with reference to a new item (52185). In that proposal, it was found that greatest dimension had the most significant impact on the transportability of those products, and classes were assigned accordingly, with corresponding class adjustments at 96- inch intervals. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AL, effective July 21, This proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 6, Page 8 of 8

53 SUBJECT 7 Re: Stone Blocks, Pieces or Slabs Staff Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class GRAVEL OR STONE GROUP: subject to item * Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone, coquina or cast stone, NOI, see Notes, items 90502, and 90504: Sub 1 Mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks, see Notes, items Sub 2 and In boxes or crates, or on lift truck skids, pallets or platforms, other than as set forth in sub 1, see Notes, items and * NOTE Not Involved * NOTE Not Involved * NOTE Not Involved * NOTE Not Involved * NOTE Applies on stone blocks, pieces or slabs secured on lift truck skids, pallets or platforms or shipping carriers or racks in a diagonal or vertical orientation * NOTE Not Involved. *Published in Supplement 1 to NMF 100-AL, issued on March 15, 2012 with an effective date of April 14, Proposed Classification Provisions Item Description Class GRAVEL OR STONE GROUP: subject to item Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone, coquina or cast stone, NOI, see Notes, items 90502, and 90504: Sub 1 Mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks, see Notes, items Sub 2 and In boxes or crates, or on lift truck skids, pallets or platforms, other than as set forth in sub 1, see Notes, items and 90509: Sub 3 Exceeding 96 inches in length Sub 4 Not exceeding 96 inches in length Subject 7, Page 1 of 6

54 SUBJECT 7 Proposed Classification Provisions Concluded Item Description Class NOTE No Change NOTE No Change NOTE No Change NOTE No Change NOTE Applies on stone blocks, pieces or slabs, boxed or other than boxed, secured and oriented diagonally or vertically on lift truck skids, pallets or platforms or shipping carriers or racks NOTE No Change. Analysis Research Project 1122 and Background of Proposal This proposal is based on information developed through the continuation of Research Project The project was initiated in November of 2010 based on reports that shipments of stone blocks, pieces or slabs, as named in item 90500, specifically when tendered on A- frame shipping racks, exhibit transportation characteristics inconsistent with the then-assigned class 50. Subject 2 of Docket (January, 2012) was a proposal to amend item by assigning a class 150 on stone blocks, pieces or slabs tendered mounted in a diagonal or vertical orientation on lift truck skids, pallets or platforms or on shipping carriers or racks, and a class 55 on those tendered in boxes or crates, or on lift truck skids, pallets or platforms, not mounted in a diagonal or vertical orientation. Based on the information of record, that proposal was approved as docketed. The amended provisions first appeared in Supplement 1 to NMF 100-AL, effective April 14, During the January, 2012 CCSB meeting where that proposal was considered, interested persons in attendance noted the extreme length of many of the handling units involved, and expressed concern that that factor might not have been fully taken into account. Therefore, the research project was kept active. Subsequent analysis of the previous docket record shows that 97% of the diagonally or vertically mounted stone blocks, pieces or slabs exceed 96 inches in length. As detailed in the analysis of, and addendum to, Docket , Subject 2, the assigned class 150 took into account the respective transportation characteristics, including the loaded density of these stone blocks, pieces or slabs. On the other hand, on the previous record only 26% of stone blocks, pieces or slabs not mounted diagonally or vertically for shipment exceeded 96 inches in length. Moreover, a review of that record reveals that the assigned class 55 was based on a one-class increase from the CCSB guidelines, due to negative handling, stowing and liability considerations, but it did not take into account the length of the handling units. This proposal evaluates the data obtained in connection with the project to date with regard to the products that are not mounted diagonally or vertically for shipment, as named in sub 2 of item Subject 7, Page 2 of 6

55 SUBJECT 7 Shipments of Stone Blocks, Pieces or Slabs The stone blocks, pieces or slabs named in sub 2 of item may be shipped in boxes or crates, but are often shipped on lift truck skids, pallets or platforms (hereinafter referred to as pallets ). The shipments may contain single or multiple blocks, pieces or slabs, which when not tendered boxed or crated may or may not be covered with fiberboard, plastic film or wood. The pallets are generally built long enough to support the entire block(s), piece(s) or slab(s). Examples of shipments that are classified under sub 2 of the current provisions are shown below. Subject 7, Page 3 of 6

56 % of Figures in Interval CCSB DOCKET SUBJECT 7 Transportation Characteristics Density The information of record includes 123 shipment observations of stone blocks, pieces or slabs not mounted diagonally or vertically for shipment, as named in sub 2 of item 90500, which were submitted by shippers and carriers, and obtained during CCSB dock surveys. The densities range from 3.37 to pcf, with an average density of pcf 1. Forty-eight percent of the figures are 30 pcf or greater as shown in the frequency distribution below. Frequency Distribution 50% 48% 40% 30% 20% 10% 0% 0% 0% 1% 3% 4% 7% 5% 6% 17% 10% Density Intervals (pcf) When the data is evaluated based on the handling unit s length, the following density ranges and averages emerge. Handling Unit Length Density Range (pcf) Average Density (pcf) Percentage of Figures Exceeding 96 inches % Not exceeding 96 inches % Handling Extra care and attention is necessary when handling stone blocks, pieces or slabs, as evidenced by the precautionary markings, Fragile, Handle with Care, Must Use Fork Extensions, and This End Up. When the length exceeds 96 inches, additional equipment, such as fork extensions, or additional personnel may be necessary to safely handle the freight. 1 The average density on the record of Docket , Subject 2 was pcf. Subject 7, Page 4 of 6

57 SUBJECT 7 Stowability Stone blocks, pieces or slabs will likely require floor loading due to the weight. When not mounted diagonally or vertically for shipment, the freight will generally provide a regular load-bearing surface, although some handling units are marked with shippers instructions, Do Not Double Stack. The information of record shows that while the majority of these handling units do not exceed 96 inches in length, many do, as previously noted. Handling units that exceed 96 inches in length present additional stowing considerations. Liability Stone blocks, pieces or slabs are susceptible to damage, particularly when not in boxes or crates or not adequately protected by packaging materials, such as fiberboard or wood. Many shipments are labeled with instructions to the consignee to inspect the freight for damage before accepting the shipment or are labeled High Claim Value. Four shippers report two claims or fewer per year. Although one carrier no longer handles this freight due to high claims ratios, other carriers did not indicate a significant claims problem. The value per pound of the units in question ranges from $0.04 to $5.71, with an average of $1.03 per pound. Note, Item Based on the transportation characteristics evaluated in Docket , Subject 2, Note, item was established. The Note defines the term Mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks. During the time this Note has been in effect, some interpretation inquiries have been received by the CCSB as to the application of these provisions. Clarifying the verbiage of the Note may assist in mitigating such interpretation requests in the future. Relationship to CCSB Policies and Guidelines During the consideration of Subject 2 of Docket , it was questioned whether or not the excessive length of certain handling units of stone blocks, pieces or slabs had been fully taken into account. As discussed in the Analysis herein, the length of handling units of these products when not mounted diagonally or vertically for shipment, as named in sub 2 of item 90500, was not specifically considered in that proposal. The information of record includes 123 shipment observations of stone blocks, pieces or slabs not mounted diagonally or vertically for shipment. The range in density is from 3.37 to pcf, with an average density of pcf. An average density of pcf is generally associated with a class 60, which under CCSB guidelines calls for a minimum average density of 30 pcf. Stone blocks, pieces or slabs are inherently liable to damage. When tendered in boxes or crates or adequately protected by packaging materials, the risk of damage may be mitigated; nevertheless, extra care and attention is necessary when handling and stowing these products, as evidenced by such precautionary markings or instructions as Fragile, Handle with Care, Must Use Fork Extensions, This End Up and Do Not Double Stack. As discussed in the Analysis section, handling units of stone blocks, pieces or slabs that exceed 96 inches in length, result in additional, negative handling and stowing characteristics. Subject 7, Page 5 of 6

58 SUBJECT 7 CCSB policies state that classification provisions should reflect a commodity s transportation characteristics. Based on the information of record, it would be in keeping with CCSB policies to amend item to provide classes based on length for stone blocks, pieces or slabs not mounted diagonally or vertically for shipment, as named in sub 2 of the item. In view of their respective transportation characteristics, handling units not exceeding 96 inches in length would be assigned a class 60 one class higher than that called for under CCSB guidelines and handling units exceeding 96 inches in length would be assigned a class 77.5 two classes higher than that called for under CCSB guidelines. The associated average densities and classes are shown in the table below. Handling Unit Length Exceeding 96 inches Not exceeding 96 inches Average Density (pcf) CCSB Minimum Average Density Guideline (pcf) Class Based on CCSB Guidelines Class Adjustment Based on Handling, Stowability and Liability Considerations Note, item would be amended to provide additional clarification for stone blocks, pieces or slabs mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks. This proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 7, Page 6 of 6

59 SUBJECT 8 Re: Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets; Containers, liquid or beverage serving; or Coolers or Cooling Boxes, beverage, containing refrigerant; hand portable, expanded plastic Staff Contact: George M. Beck Telephone (703) beck@nmfta.org Proponent: Lifoam Industries, LLC, Hunt Valley, Maryland Present Classification Provisions Item Description Class PLASTIC OR RUBBER ARTICLES OR MATERIALS, EXPANDED, GROUP: subject to item Articles, Forms or Materials, viz.: [Articles Listed Not Involved.] In bags, boxes or drums, 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 or greater NOTE Not Involved NOTE Not Involved NOTE Not Involved Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets; Containers, liquid or beverage serving; hand portable, with or without components or affixed accessories of other materials, in boxes: Sub 1 With integral refrigerant gel filled lid Sub 2 Other than with integral refrigerant gel filled lid Coolers or Cooling Boxes, beverage, hand portable, containing refrigerant, with or without cloth carrying bag, in boxes, having a density in pounds per cubic foot of 5 or greater, see Note, item NOTE Density must be shown by the shipper on shipping orders and bills of lading at time of shipment. If density is not shown and shipment is inadvertently accepted, charges will initially be assessed under the provisions for 'Expanded Plastic Boxes, cooling, NOI,' per item Upon satisfactory proof of actual density, freight charges will be adjusted accordingly. Subject 8, Page 1 of 6

60 SUBJECT 8 Proposed Classification Provisions Item Description Class PLASTIC OR RUBBER ARTICLES OR MATERIALS, EXPANDED, GROUP: subject to item Articles, Forms or Materials, viz.: Boxes or Chests, cooling, NOI, or Coolers, NOI, hand portable; Containers, liquid or beverage serving, hand portable; Ice Buckets; [Other Articles Listed No Change.] In bags, boxes or drums, 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 or greater NOTE No Change NOTE No Change NOTE No Change Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets; Containers, etc... Cancel; see item Coolers or Cooling Boxes, beverage, hand portable, etc... Cancel; see item NOTE Cancel; no further application. Analysis This proposal was docketed to address interpretation disputes between the proponent and its various carriers on shipments of the proponent s coolers; in particular, those coolers represented as Koolit Bags. According to the proponent, the carriers are applying four different classification provisions. The CCSB has issued opinions that the applicable classification provisions are in item , as shown in the present provisions herein. History of Provisions The provisions of item were established as a result of action taken on Docket 703, Subject 50 (May 1970), and first appeared, with a class 400, in Supplement 27 to NMFC A- 11, effective May 31, The coolers or cooling chests on that record produced a range in density from 0.37 to 2.18 pcf, with an average density of 1.11 pcf. The ice buckets on that record ranged from 0.81 to 1.31 pcf (two figures), with an average of 1.05 pcf. Subject 8, Page 2 of 6

61 SUBJECT 8 As a result of action taken on Docket 734, Subject 27 (July 1973), item was amended to add a subprovision for products with integral refrigerant gel-filled lids at class 250, and the class 400 was retained for those products without integral refrigerant gel-filled lids. This change first appeared in Supplement 4 to NMF 100-A, effective June 21, Item was established as a result of action taken on Docket 742, Subject 47 (March 1974), and first appeared in Supplement 1 to NMF 100-B, effective April 1, The involved coolers had densities from 5.70 to 6.60 pcf. About Expanded Plastic Coolers, Ice Buckets, etc. Expanded plastic hand portable cooling boxes or chests, coolers, ice buckets and liquid or beverage serving containers were originally an inexpensive alternative to such products made of other materials. Their light weight made them easy to carry. They are generally used to keep beverages and other items cold. Examples of the coolers and ice buckets embraced by item are shown below: The following is a picture of the cooler with refrigerant core that established item : Subject 8, Page 3 of 6

62 SUBJECT 8 The proponent s products include the following expanded plastic coolers: The proponent s products are manufactured from expanded plastic with or without components of other materials. As previously mentioned, the proponent s Koolit Bags have been the subject of interpretation questions. They are constructed with a vinyl exterior, a thin layer of expanded plastic, which is the primary construction material and insulating medium, and a non-expanded plastic handle. These coolers are collapsed and folded in inner containers when shipped, as shown below. Subject 8, Page 4 of 6

63 % of Figures in Interval CCSB DOCKET SUBJECT 8 Transportation Characteristics Density The data furnished by the proponent yields two density figures: 1.07 and 3.93 pcf. In addition, the CCSB Density Study 1 contains 126 density figures for products reported to be moving under items and , ranging from 0.33 to pcf. The average density of all figures is 3.62 pcf. A frequency distribution is shown below. Frequency Distribution 45% 40% 35% 30% 25% 20% 15% 10% 5% 0% 7% 14% 43% 27% 5% 4% 1% 0% 0% 0% 0% Density Intervals (pcf) Handling The information of record indicates that the involved articles are generally tendered for shipment in fiberboard boxes of regular size and shape and palletized. No unusual or significant negative handling considerations have been identified. Stowability The information of record does not suggest that stowability of these articles presents any significant negative considerations. However, as with other lightweight and foam plastic products, consideration should be given as to where the articles are stowed to avoid crushing. In this regard, the proponent states that these articles are actually used in many cases as top freight. Liability The proponent s information indicates that the average value per pound for these products is between $5.00 and $5.35. Proponent also states that claims for these products are less than 0.05% a year. 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 8, Page 5 of 6

64 SUBJECT 8 Relationship to CCSB Policies and Guidelines This proposal would cancel items and and name the involved commodities in item , which provides classes based on the CCSB s standard nine-subprovision density scale that ranges from class 400 for densities of less than 1 pcf to class 70 for densities of 15 pcf or greater 2. CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record for items and indicates a range in density from 0.33 to pcf, with an average density of 3.62 pcf. Under CCSB policy, commodities exhibiting a wide range in density may be assigned density-based classes; especially when there are no unusual handling, stowability or liability characteristics. Canceling items and and incorporating these commodities in item , as proposed, is consistent with the aforementioned CCSB policy. The proponent also believes this would eliminate interpretation disputes as to the proper classification of the involved commodities, consistent with CCSB policy. 2 The CCSB s standard nine-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 8, Page 6 of 6

65 SUBJECT 9 Re: Waste Receptacles, steel or concrete Staff Contact: Allison L. Austin Telephone (703) austin@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class Holders or Receptacles, refuse, perforated steel or steel frame, with mounting hardware, with or without wood slatted exterior, with or without plastic or sheet steel liner, in boxes Holders or Receptacles, refuse or waste, cast concrete with wire reinforcement, with or without tops or liners of other materials, on pallets SHEET STEEL ARTICLES GROUP: subject to item Baskets, NOI, Wastebaskets or Dry Measures, in packages: Sub 1 Not nested Sub 2 Nested Cans, ash, garbage, oiled waste, refuse, NOI, or disposal, with or without bails or covers, in packages: Sub 1 Nested, NOI, or not nested Sub 2 Nested, subject to Item 170 and having a density of 6 pounds or greater per cubic foot Receptacles, refuse or refuse bag, not over 12 cubic feet capacity, with permanently attached tops or with self-closing tops, with or without liners, in boxes or crates: Sub 1 SU Sub 2 KD flat Proposed Classification Provisions Item Description Class Holders or Receptacles, refuse, perforated steel or steel frame, etc... Cancel; see item B-NEW Holders or Receptacles, refuse or waste, cast concrete with wire reinforcement, etc... Cancel; see item A-NEW A-NEW Receptacles or Holders, waste or refuse, cast concrete, with or without tops, liners or mounting hardware of same or other materials, in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 12 or greater Subject 9, Page 1 of 9

66 SUBJECT 9 Proposed Classification Provisions Concluded Item Description Class SHEET STEEL ARTICLES GROUP: subject to item Baskets, NOI, or Dry Measures, in packages: Sub 1 Not nested... No Change Sub 2 Nested... No Change Cans, ash, garbage, oiled waste, refuse, NOI, or disposal, with or without bails or covers, etc... Cancel; see item B-NEW B-NEW Cans, Receptacles or Holders, waste or refuse, or Wastebaskets, with or without tops, liners or mounting hardware of same or other materials, see Note, item C-NEW, in boxes or crates C-NEW NOTE Also applies on such products of steel frame construction, with or without wood slatted exterior Receptacles, refuse or refuse bag, not over 12 cubic feet capacity, with permanently attached tops or with self-closing tops, with or without liners, etc.... Cancel; see item B-NEW Analysis Research Project 1143 This proposal is based on information developed through Research Project 1143, pertaining to waste or refuse cans, receptacles or holders, and wastebaskets. Herein these products will be referred to as waste receptacles. Research Project 1143 was initiated by the CCSB in October 2011, in light of existing interpretation disputes. There are several waste receptacle entries in the NMFC, with provisions largely based on material consist and/or industry terminology. This proposal is limited to waste receptacles constructed of steel or concrete. It should be noted that the project originally encompassed waste receptacles of aluminum or plastic construction as well. However, very limited data was obtained on products made of these materials, and it is uncertain if the data received is representative of the current transportation characteristics of those commodities. Consequently, this proposal does not address aluminum or plastic waste receptacles. Commodity questionnaires were sent to 343 potential manufacturers or shippers of waste receptacles and three associations believed to represent those companies in October, and for those that did not respond, again in December of Six questionnaires were returned as undeliverable, 22 companies responded that they do not manufacture or ship waste receptacles, three companies indicated that they do not ship via less-than-truckload (LTL) and 29 companies provided information, 15 of which provided usable information on steel or concrete waste receptacles. No responses were received from the associations contacted. Subject 9, Page 2 of 9

67 SUBJECT 9 Additional information of record was developed through CCSB dock surveys, carriersubmitted Shipment Information Forms and the CCSB s Density Study 1. History of Provisions Item 99815, naming Holders or Receptacles, refuse, perforated steel or steel frame, was established as a result of action taken on Subject 24 of Docket 797 (October 1979), and first appeared in Supplement 7 to NMF 100-G, effective August 16, That proposal was approved as modified; and information on that record indicated an average density of 9 pcf and no unusual or significant handling, stowability or liability characteristics. The provisions have remained substantially unchanged to the present. Item 99817, naming Holders or Receptacles, refuse or waste, cast concrete with wire reinforcement, was established as a result of action taken on Subject 16 of Docket 812 (March 1981), and first appeared in Supplement 9 to NMF 100-H, effective October 10, Information on that record indicated an average density of 40 pcf and no unusual or significant handling or liability characteristics; although, some stowability issues were identified due to the lack of a regular load-bearing surface for top freight. The proposal was approved as modified, and the provisions have remained substantially unchanged to the present. The noun Wastebaskets was added to the description of item , and the present classes were established in the item, as a result of action taken on Subject 103 of Docket 74 (June 1956) and Subject 52 of Docket 77 (January 1957). The addition of the noun Wastebaskets first appeared in Supplement 5 to NMFC A-4, effective August 12, The present classes first appeared in Supplement 9 to NMFC A-4, effective November 4, The provisions have remained substantially unchanged to the present. The current subprovisions of item , applying on sheet steel Cans, ash, garbage, oiled waste, refuse, NOI, or disposal, were established as a result of action taken on Subject 16 of Docket 898 (December 1989), and first appeared in Supplement 9 to NMF 100-P, effective February 17, The proposal established a reduced class (125) for nested cans having a density of 6 pcf or greater, per sub 2 of the item. Information on that record revealed a density range of 6.32 to 13.8 pcf, with an average density of 8.44 pcf. There was no indication of handling or stowability problems, and value per pound ranged from $0.72 to $3.52, with an average of $1.50 (in 1989 dollars). Nested cans, NOI, or cans not shipped nested remained at the previously assigned class (175), per sub 1. The current provisions of item , applying on sheet steel Receptacles, refuse or refuse bag, are a result of action taken on Subject 30 of Docket 803 (April 1980), and first appeared in Supplement 9 to NMF 100-G, effective October 11, The proposal established a reduced class (125) for receptacles shipped SU, per sub 1 of the item. Shipment 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 9

68 SUBJECT 9 densities on that record ranged from 5.33 to pcf, with a weighted average density of 7.41 pcf. About Waste Receptacles The involved commodities are waste receptacles constructed of steel or concrete. As shown in the examples below, these waste receptacles vary in size, design and area of usage. The products encompass those utilized in the public space, including on street corners, parks and shopping malls, as well as those used in offices or homes. Although industry terminology varies as to the name of these commodities they all serve comparable functions. Shipments of Waste Receptacles The photos below and on the next page illustrate just a few of the ways waste receptacles are tendered for shipment. Steel Subject 9, Page 4 of 9

69 % of Figures in Interval CCSB DOCKET SUBJECT 9 Concrete Transportation Characteristics Density Overall, information of record includes 2,263 density observations for waste receptacles. When these products are separated by material consist, 2,002 density figures emerge for steel waste receptacles. The steel products range in density from 1.04 to pcf, with a simple average density of 5.48 pcf. A frequency distribution for steel waste receptacles is shown below. Steel Waste Receptacles Frequency Distribution 35.00% 30.00% 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 3.60% 31.82% 28.02% 27.57% 4.35% 1.90% 1.05% 0.95% 0.40% 0.35% Density Intervals (pcf) As the above frequency distribution depicts, the density observations for steel waste receptacles are distributed throughout the range. However, over 87% of the figures are between 2 and 8 pcf. Subject 9, Page 5 of 9

70 % of Figures in Interval CCSB DOCKET SUBJECT 9 Information of record for concrete waste receptacles is based on 261 density figures. These concrete products range in density from 4.22 to pcf, with a simple average density of pcf. As shown in the frequency distribution below, while the densities are distributed throughout the density range, there are two spikes, or clusters, of densities within the density range. The first is the 6 but less than 8 pcf interval representing 18.39% of the density observations, and the second is the 15 but less than 22.5 pcf interval representing 22.99% of the density observations. Concrete Waste Receptacles Frequency Distribution 25.00% 22.99% 20.00% 18.39% 15.00% 10.00% 5.75% 7.28% 6.51% 10.73% 14.18% 14.18% 5.00% 0.00% 0.00% 0.00% 0.00% Density Intervals (pcf) When the data for concrete waste receptacles is evaluated on the basis of the proposed density break at 12 pcf, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling Waste receptacles are tendered for shipment in a variety of ways, including in fiberboard boxes which may or may not be palletized, packaged in a crate, wrapped in plastic film on a lift truck skid or pallet, strapped to a lift truck skid or pallet, or loose. Freight boxed, crated or tendered on lift truck skids or pallets will generally provide better handling than that tendered loose 2. However, no unusual handling considerations have been reported. 2 While some of the involved products are shown to be tendered loose, the present provisions do not authorize loose shipments. Subject 9, Page 6 of 9

71 SUBJECT 9 Stowability Generally, when tendered in boxes or crates, a flat load-bearing surface will be present for loading other freight on top; however, some shippers instruct carriers to Do Not Stack. Greater stowability problems may exist when the waste receptacle is tendered wrapped or strapped to a pallet or loose, as other freight may not be top-loaded because of the absence of a regular load-bearing surface. Nevertheless, no specific stowability issues have been reported by carriers. Liability Waste receptacles are not perishable, prone to spontaneous combustion or explosion, or unusually susceptible to theft. One carrier that is unable to provide a claims ratio specific to these products notes that dents and scratches to waste receptacles have been reported when tendered loose or without sufficient interior packing materials. As is the case with other general commodities, waste receptacles tendered in boxes, crates or on lift truck skids or pallets will be afforded greater protection against damage than those tendered loose. When necessary, per Item (Rule) 680, Sec. 1(a), interior packing must be provided to give adequate protection against damage to the freight. A second carrier reports a claims ratio of 0.06% for product shipments moving under item and 0.55% for shipments moving under item 99817, both below the 1% threshold considered typical for LTL freight operations. Responding shippers have indicated a limited number of claims on these commodities. A limited amount of information on the value of these commodities reveals a range from $1.12 to $43.54 per pound, with an average value of $7.24 per pound for steel waste receptacles, and a range from $0.77 to $3.25 per pound, with an average value of $1.63 per pound for concrete waste receptacles. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to be as clear as possible to mitigate the potential for interpretation disputes, combining descriptions embracing related commodities and uniformity in provisions addressing the same or similar circumstances. The present language and structure of provisions applying on waste receptacles is incongruous. Items 99815, , and all apply on waste receptacles constructed of steel, but are inconsistently named and described throughout the Classification, resulting in interpretation issues. These interpretation issues could be mitigated by combining the descriptions for the related commodities. Combining these related commodities for simplification and uniformity would be in keeping with CCSB policy. CCSB policy also calls for provisions to reflect a commodity s known transportation characteristics. Information of record for steel waste receptacles shows a range in density from 1.04 to pcf, with an average density of 5.48 pcf. As shown in the frequency distribution on page 5, a predominant concentration of density figures for steel waste receptacles are within a narrow range around the overall average. Under CCSB guidelines, an average density of 5.48 pcf is generally associated with a class 175, which calls for a minimum average density of 5 pcf. Subject 9, Page 7 of 9

72 SUBJECT 9 Removing Wastebaskets from item and canceling items 99815, and with reference to a new item for sheet steel Cans, Receptacles or Holders, waste or refuse, or Wastebaskets, at class 175, reflective of the overall average density of these commodities, would be in keeping with CCSB policy and precedent. Such an approach would be consistent with action taken on Docket , Subject 2 (October 2009), involving item 28160, for footwear. No significant negative handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. As with steel waste receptacles, footwear was shown to exhibit a wide range of densities from 1.00 to pcf with a significant concentration of the density observations almost 78% clustered around the overall average density of 6.28 pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal was approved as docketed, assigning class 150, and the provisions first appeared in Supplement 5 to NMF 100-AI, effective January 9, A new Note would also be added to provide for waste receptacles on a steel frame, with or without a wood slatted exterior. Information of record for concrete waste receptacles reveals a range in density from 4.22 to pcf, with an average density of pcf. According to CCSB density guidelines, an average density of pcf is generally associated with a class 70, which calls for a minimum average density of 15 pcf. However, CCSB policies further state that when commodities exhibit a wide range in density that is not accurately reflected by a single class, density-based provisions may be established. As shown in the frequency distribution on page 6, there are two spikes, or clusters, of densities within the overall density range. When the data of record is evaluated on that basis, with a density break at 12 pcf, the following density groupings and class assignments emerge. Density Group (pcf) Average Density (pcf) Guideline Class Density Guideline (pcf) Less than or greater Canceling the provisions of item 99817, for cast concrete waste receptacles, and establishing a new item for Receptacles or Holders, waste or refuse, cast concrete, with a density break at 12 pcf 3, reflective of the two spikes within the overall density range, would be in keeping with CCSB policy and precedent. A similar approach was taken on Docket , Subject 11 (June 2009), involving engine radiator, fuel tank or oil filler caps, as named in item No significant negative 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 density range of 2.96 to pcf, there were two spikes, or clusters, of densities within the overall density range. Thus, a single density break was proposed to provide a more accurate reflection of the identified range in density. That proposal was approved as docketed, and the provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 9, Page 8 of 9

73 SUBJECT 9 Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 9, Page 9 of 9

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75 SUBJECT 10 Re: Partitions or Partition Doors, steel and wire combined Staff Contact: Daniel E. Horning Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING METALWORK GROUP: subject to item Partitions or Partition Doors, steel and wire combined, in sections or panels FENCING GROUP: subject to item Fencing, NOI, or Fence Gates, other than plastic, in packages, 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 Proposed Classification Provisions Item Description Class BUILDING METALWORK GROUP: subject to item Partitions or Partition Doors, steel and wire combined, etc... Cancel; see item FENCING GROUP: subject to item Fencing, NOI, or Fence Gates, other than plastic; or Partitions or Partition Doors, steel and wire combined; in packages, 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 Analysis This proposal originated from Research Project 1160, which was initiated in March, 2012 in response to an interpretive request from a member carrier questioning whether or not steel and wire partitions are properly classified as fence panels, per item 68025, or as partitions, per item (as held by the CCSB). Information submitted by the carrier indicated densities between 6 and 8 pcf for shipments tendered on lift truck skids or pallets, which is inconsistent with the currently assigned class 77.5 provided in item CCSB guidelines for class 77.5 call for a minimum average density of 13.5 pcf. Research Project 1160 During the course of Research Project 1160, questionnaires regarding the transportation characteristics of partitions or partition doors of steel and wire construction were sent to 12 Subject 10, Page 1 of 5

76 SUBJECT 10 associations and 67 potential manufacturers or shippers in May, and for non-respondents, July of From these mailings, only one shipper furnished any usable information. One association, the Steel Manufacturers Association, confirmed their members are involved with the transportation of the subject commodities, but did not provide any data. Additional information was developed through the CCSB s Density Study 1 and dock surveys, along with carrier-submitted reports. History of Provisions Provisions for partitions or partition doors of steel and wire construction were adopted from the rails in The entry has remained substantially unchanged save for the removal of the term flat from the description to address possible interpretative difficulties with shipments in sections or panels. This change was the result of action taken on Subject 132 of Docket 125 (September, 1966), and first appeared in Supplement 9 to NMFC A-9, effective May 17, Item was established as a result of action taken on Subject 1 of Docket 898 (December, 1989), which established the Fencing Group as a new generic grouping. The current provisions were established as a result of action taken on Docket , Subject 1 (February, 2009). Most notably, item was established and restricted to wire fencing in rolls, while item was amended as an NOI entry to cover all other forms, including shipments in panels or sections. The provisions first appeared in Supplement 2 to NMF 100-AI, effective April 25, About Partitions or Partition Doors Steel and wire mesh partitions as named in item are modular units that, like fence panels, provide a defined space and/or provide security for a variety of applications. They can resemble cages or enclosures, depending upon how and where used, and are assembled from panels or sections, with one or more doors. Typical examples include storage or service enclosures, tool cribs, robotic barriers, or pharmaceutical cages, as depicted below. Interpretations initially held the products to be classified as fencing, per item 68025, but later upon reconsideration those opinions were rescinded and the products were held to be classified under the specific provisions of item 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 10, Page 2 of 5

77 % of Figures In Interval CCSB DOCKET SUBJECT 10 Transportation Characteristics Density The information of record includes 533 density figures ranging from 1.25 to pcf, for an average of 9.39 pcf. As depicted in the graph below, the densities are distributed throughout the range % 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 0.38% Frequency Distribution 16.17% 12.59% 14.47% 28.57% 12.41% 6.39% 5.45% 1.88% 1.69% Density Intervals (pcf) A comparison of fence panels or gates (from the record of Docket , Subject 1) and partitions or partition doors is shown below. Table 1 Fence Panels or Gates Density Group (pcf) Table 2 Partitions or Partition Doors Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Density Range (pcf) Less than but less than or greater Average Density (pcf) Handling Carrier reports indicate that product shipments can exceed 96 inches in length. Generally, freight that exceeds 96 inches in length will require extra care and attention during handling. Subject 10, Page 3 of 5

78 SUBJECT 10 Stowability Just as with fencing, when tendered in an upright position or without protective packaging on lift truck skids or pallets, partitions may be more difficult to stow than general boxed freight. Carriers may be restricted to floor loading and might not be able to stack freight on top due to the lack of a load-bearing surface. Some shipments are labeled with precautionary markings or instructions such as Do Not Double Stack. Liability These commodities are not perishable, susceptible to theft or prone to spontaneous combustion or explosion. They may be liable to damage during transit when tendered on lift truck skids or pallets and not adequately protected by packaging. The value per pound is unknown, while carrier claims personnel did not indicate any claims issues. Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions 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 mentioned, there has been some question as to the applicable NMFC provisions for the subject commodities; in particular, between item 36890, which names partitions or partition doors, and item 68025, which names fencing or fence gates. The terms apply on very similar, if not identical, articles. Canceling item with reference to item 68025, and naming steel and wire partitions or partition doors in item 68025, as proposed, would address the interpretation issue. It is also CCSB policy that provisions reflect a commodity s known transportation characteristics. The information of record shows that partitions or partition doors exhibit a density range from 1.25 to pcf, for an average of 9.39 pcf, along with some handling, stowability and liability concerns. The density range is consistent with the range of densities considered in the establishment of the present provisions in item for fencing or fence gates 2, along with comparable handling, stowing and liability characteristics. (A commensurate one-class adjustment was made to item to reflect the impact of negative handling, stowing and liability concerns.) A comparison of fence panels or gates (from the record of Docket , Subject 1) and partitions or partition doors is shown on the next page. 2 The density-based provisions of item include reference to Item (Rule) 170, the inadvertence clause. Subject 10, Page 4 of 5

79 SUBJECT 10 Table 3 Fence Panels or Gates Density Group Density (pcf) Range (pcf) Average Density (pcf) Class Based on CCSB Guidelines Class Based on One-Class Increase Less than but less than or greater Table 4 Partitions or Partition Doors Density Group Density (pcf) Range (pcf) Average Density (pcf) Class Based on CCSB Guidelines Class Based on One-Class Increase Less than but less than or greater For these reasons, this proposal is consistent with CCSB policy and precedent. Subject 10, Page 5 of 5

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81 SUBJECT 11 Re: Screen Doors or Window Screens Staff Contact: William F. Mascaro Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Screens, window, adjustable, metal screen cloth in frames consisting of metal top and bottom members (rails) and wooden ends, in boxes.. 85 BUILDING METALWORK GROUP: subject to item Screen Doors or Window Screens, NOI, see Note, item 37082, in packages NOTE Shipments in bundles must have screening protected Screens or Barriers, window or door, detention or security, see Note, item 37087, in packages NOTE Applies only on metal frames with wire cloth or perforated metal screening used on building windows or doors to provide security, protection or safety Screens, window, tension type, not framed, aluminum or aluminum with steel wire screen cloth, in boxes BUILDING WOODWORK GROUP: subject to item Frames, screen door or window screen, wooden, KD, with or without metal fittings, in packages Screen Doors or Window Screens, see Note, item 38152, in packages NOTE Shipments in bundles must have screening protected. Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Screens, window, adjustable, metal screen cloth in frames consisting of metal top and bottom members (rails) and wooden ends, etc... Cancel; see item A-NEW A-NEW Screen Doors or Window Screens, NOI; or Screens or Barriers, door or window, detention or security, 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 6 but less than Sub 3 10 or greater B-NEW NOTE Applies on metal frames with wire cloth or perforated metal screening used on building doors or windows to provide security, protection or safety. Subject 11, Page 1 of 7

82 SUBJECT 11 Proposed Classification Provisions Concluded Item Description Class BUILDING METALWORK GROUP: subject to item Screen Doors or Window Screens, NOI, etc... Cancel; see item A-NEW NOTE Cancel; no further application Screens or Barriers, window or door, detention or security, etc... Cancel; see item A-NEW NOTE Cancel; see item B-NEW Screens, window, tension type, not framed, aluminum or aluminum with steel wire screen cloth, etc... Cancel; see item A-NEW BUILDING WOODWORK GROUP: subject to item Frames, screen door or window screen, wooden, KD, with or without metal fittings, etc... Cancel; see item A-NEW Screen Doors or Window Screens, etc... Cancel; see item A-NEW NOTE Cancel; no further application. Analysis Research Project 1139 This proposal is based on information developed through Research Project 1139, which was initiated in August 2011 to investigate the transportation characteristics of screen doors or window screens, as classified in items 35310, 37080, 37085, 37090, and As part of the research, 513 potential manufacturers or shippers and nine trade associations were contacted in January 2012, and for those that did not respond, again in April 2012, inviting them to participate. From this sampling, 31 of the shipper surveys were returned as undeliverable, 67 companies responded that they did not manufacture or ship the involved articles, and 10 companies provided at least some information. Not all of the information was usable, however. With respect to the associations, one survey was returned as undeliverable, three associations responded that they did not represent manufacturers or shippers of the involved articles, and one association refused delivery of the survey. No response was received from the remaining four associations. History of Provisions The provisions of item 35310, applying on Screens, window, adjustable, metal screen cloth in frames consisting of metal top and bottom members (rails) and wooden ends, were established as a result of action taken on Docket 722, Subject 54 (March 1972). That was a proposal to establish a specific provision for these screens in lieu of them being classified under item 37080, Screen Doors or Window Screens, NOI. The proposal was approved as modified, and the provisions first appeared in Supplement 4 to NMF 100, effective March 2, Subject 11, Page 2 of 7

83 SUBJECT 11 The current provisions of item 37080, applying on metal Screen Doors or Window Screens, NOI, and item 37085, applying on Screens or Barriers, window or door, detention or security, were established as a result of action taken on Docket 964, Subject 8 (November 1996). That was a proposal to amend item to remove its reference to other than detention or roller, and to amend item to name Screens or Barriers, window or door, detention or security. The proposal was approved as docketed, and the changes first appeared in Supplement 6 to NMF 100-W, effective January 18, The current provisions of item 37090, applying on Screens, window, tension type, not framed, aluminum or aluminum with steel wire screen cloth, were established as a result of action taken on Docket 58, Subjects 63 and 77 (April 1953), and first appeared in Supplement 17 to NMFC A-1, effective November 17, The supporting documentation for this change is no longer available. The provisions of item 37930, Frames, screen door or window screen, wooden, KD, with or without metal fittings, were adopted from the rails in 1936 and have remained substantially unchanged to the present. The current provisions of item 38150, for wooden Screen Doors or Window Screens, were established as a result of action taken on Docket 138, Subject 56 (January 1969), and first appeared in Supplement 29 to NMFC A-10, effective January 21, About Screen Doors and Window Screens Screen doors and window screens are used in houses and other buildings to keep insects and other pests out while allowing light and air to enter. They may be fixed in place, like many window screens, or hinged or on wheels to allow egress into and out of the structure. Screen doors or window screens are generally made from a metal or wood frame with either aluminum or fiberglass mesh in the frame opening. (Detention or security screens or barriers tend to be of more-robust construction.) Their size will vary depending upon the application. Transportation Characteristics Density The information of record encompasses 1,631 density observations from a variety of sources, including shipper- and carrier-supplied data, CCSB dock surveys, and the CCSB s Density Study 1. The densities range from 0.60 to pcf, with a simple average density of 8.06 pcf. A frequency distribution of the overall density range is provided 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 TM 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 7

84 % of Figures in Interval CCSB DOCKET SUBJECT % 18.00% 16.00% 14.00% 12.00% 10.00% 8.00% 6.00% 4.00% 2.00% 0.00% Frequency Distribution 19.13% 19.37% 17.96% 13.86% 9.87% 5.70% 5.33% 5.21% 0.49% 1.53% 1.53% Density Intervals (pcf) As can be seen in the density distribution, while the densities are distributed throughout the range, they are grouped within three clusters of less than 6 pcf, 6 but less than 10 pcf, and 10 pcf or greater. The table below provides an evaluation of the densities on the basis of these three density groups. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than to but less than to or greater to The table below provides a breakdown of the densities of record on the basis of the reportedly applicable item number. Item Number Density Range (pcf) Average Density (pcf) to to to to to to As depicted in the table above, the density ranges for each item overlap. Subject 11, Page 4 of 7

85 SUBJECT 11 Handling Screen doors and window screens are generally lightweight and may require extra care and attention when loading, unloading and in cross-dock operations. The information developed indicates that most screen doors and window screens are tendered in boxes that may be palletized for shipment. When palletized they are frequently placed within a wooden framework built on or around the pallet or in an A-frame-type shipping container. Many of the packages provide directional arrows and other handling instructions. While not appearing to be the norm, not all screen doors or window screens are tendered on pallets or provide for mechanical handling. Stowability Information of record indicates that screen doors or window screens are packaged and tendered for shipment in different manners, including secured flat on pallets, mounted on edge on pallets, or enclosed within packaging material but not on pallets. When mounted on edge, screen doors or window screens are typically braced with diagonal bracing resembling an A-frame-type package, or with some other method of bracing to support the screen in position. Regardless of the manner in which the screen door or window screen is tendered for shipment, several negative stowing considerations have been identified. When placed flat on a pallet, extra care and attention will have to be given to ensure that any freight loaded on top of the screen doors or window screens is compatible to minimize the potential for damage. Screen doors or window screens mounted on edge, whether or not on a pallet, will lack a flat load-bearing surface for other freight. The impact of this on the carrier s ability to load other freight may be lessened somewhat due to the height of the screen, especially in the case of screen doors; nevertheless, the space above the package is essentially unusable. Screen doors or window screens tendered in this manner will also typically require floor loading, which will further inhibit the carrier s ability to utilize available vehicle space due to the inability to tier shipments. As previously mentioned, the involved screen doors or window screens are also often mounted on a pallet and a supporting framework is built around them. This framework may consist of diagonally affixed boards to support the screen, or some type of vertical framework, and often results in an irregularly shaped package. Subject 11, Page 5 of 7

86 SUBJECT 11 The manner in which the screen door or window screen is packaged and tendered to the carrier for shipment presents not only negative stowing considerations due to the inability to efficiently use the available vehicle space, it also has a detrimental impact on the density of the screen. Additionally, screen doors or window screens tendered in this manner will require extra care and attention when loading freight adjacent to them to ensure that shifting during transit does not occur, which might break the supports or damage the screen, especially as these packages offer little or no lateral support to adjacent freight. This increases the difficulty in structuring the load within the vehicle. Liability Screen doors or window screens are not perishable, prone to spontaneous combustion or explosion or unusually susceptible to theft. With respect to damage, screen doors and window screens may be somewhat susceptible to damage, especially to denting, tearing and abrasion from adjacent freight. Additionally, the manner in which a screen door or window screen is tendered for shipment may also have an impact on its susceptibility to damage. As depicted in the photographs throughout this analysis, many of the methods employed by shippers when packaging their screen doors or window screens do not provide any lateral support for other freight. This is because the screen is mounted vertically in the center or on the edge of a pallet and is supported by bracing. This bracing may be of sufficient strength to hold the screen door or window screen in position, but it may not support the additional load placed on it by adjacent freight. This could result in damage to the screen. There is, however, no indication of a claims problem. A limited amount of information on the value of screen doors or window screens indicates a range from $3.16 to $4.29 per pound, with an average value of $3.72 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record reveals that screen doors or window screens are shipped in a variety of different configurations, resulting in a density range from 0.60 to pcf. CCSB policy further provides that where commodities or commodity groups exhibit a wide density range not accurately reflected by a single, overall average density, they may be assigned density-based classes. However, in this instance research has identified several significant negative handling, stowability and liability considerations that must also be considered, in accordance with CCSB policies. These have been detailed in the analysis and include such factors as the lack of a flat load-bearing surface and lack of lateral support for other freight. CCSB policy also calls for commodity descriptions to be as clear as possible to help preclude interpretation disputes. The currently applicable provisions are primarily based on the material consist of the screen door or window screen. However, screen doors or window screens are made from a variety of materials, including combinations of different materials, which may not be reflected by the existing provisions. This can result in interpretation issues as it may be difficult to determine the material consist of a given screen door or window screen by visual inspection. Establishing a new item for Screen Doors or Window Screens, NOI; or Subject 11, Page 6 of 7