Re: Ceiling or Interior Siding or Ceiling or Interior Siding Moldings, Panels or Ornaments, metal, with or without acoustical or insulating material

Transcription

1 Re: Ceiling or Interior Siding or Ceiling or Interior Siding Moldings, Panels or Ornaments, metal, with or without acoustical or insulating material Staff Contact: Daniel E. Horning Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING METALWORK GROUP: subject to item Ceiling or Interior Siding or Ceiling or Interior Siding Moldings, Panels or Ornaments, NOI, aluminum, in boxes Ceiling or Siding, or Ceiling or Siding Moldings, Panels or Ornaments, enameled, iron or steel, or wood covered with iron or steel or tin plate, see Note, item 36014, in boxes NOTE Also applies on iron or steel ceiling panels containing mineral wool (clay, rock, slag or glass wool) insulating material Ceiling or Siding, or Ceiling or Siding Moldings, Panels or Ornaments, other than enameled, iron or steel, or wood covered with iron or steel or tin plate, nested or in panels, in packages Panels or Pans, acoustical ceiling, aluminum, with or without insulating material, in boxes: Sub 1 With complement of spacers and wire grid inserts in same box Sub 2 Without spacers or wire grid inserts THIS SPACE INTENTIONALLY LEFT BLANK 2013 National Motor Freight Traffic Association, Inc. Subject 6, Page 1 of 7

2 Proposed Classification Provisions Item Description Class BUILDING METALWORK GROUP: subject to item Ceiling or Interior Siding or Ceiling or Interior Siding Moldings, Panels or Ornaments, NOI, aluminum, etc... Cancel; see Ceiling or Siding, or Ceiling or Siding Moldings, Panels or Ornaments, enameled, iron or steel, etc... Cancel; see NOTE Cancel; no further application Ceiling or Siding, or Ceiling or Siding Moldings, Panels or Ornaments, other than enameled, iron or steel, etc... Cancel; see A-NEW Ceiling or Interior Siding, or Ceiling or Interior Siding Moldings, Panels, Pans or Ornaments, metal, combined or not combined with other materials, Sub 1 see Note, item B-NEW, in boxes: Greatest dimension exceeding 96 inches, see Note, item C-NEW, 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 or greater Sub 5 Greatest dimension not exceeding 96 inches, see Note, item C-NEW, 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 or greater B-NEW NOTE Also applies on geometric or three-dimensional (3-D) panels. C-NEW NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment Panels or Pans, acoustical ceiling, aluminum, etc... Cancel; see Analysis Research Project 1140 and Background of Proposal This proposal is based on information developed through Research Project 1140 involving metal ceiling or interior siding or ceiling or interior siding moldings, panels or ornaments, with or without acoustical or insulating material. The project was initiated in September, 2011 in response to density reports, specifically on three-dimensional (3-D) geometric panels. It was reported that various descriptions were being utilized for transportation, including aluminum articles, NOI, per item 13120, and suspension ceiling grids, per item In its interpretive response, the CCSB advised a question of fact, holding item applicable for aluminum panels and item if sold as acoustic ceiling panels. Subject 6, Page 2 of National Motor Freight Traffic Association, Inc.

3 Product shipment information reported by the involved carrier included densities of less than 2 pcf. During the project, questionnaires were sent to 174 potential manufacturers or shippers and 26 trade associations related to the ceiling panel industry. Mailings were sent in November, 2011, and for non-respondents, a second, follow-up letter was sent in January, From those questionnaires, usable information was received from three companies, while 16 questionnaires were either returned as undeliverable or the companies stated they do not ship the involved products. Two associations responded indicating that they did not represent manufacturers or shippers involved in the study. Additional information was developed through the CCSB Density Study 1 and carrier-submitted reports. A proposal resulting from Research Project 1140 was considered by the CCSB at its September 10, 2012 public meeting (see Subject 9 of Docket ). At the meeting, a member carrier questioned whether or not the aspect of length had been duly considered and sufficient weight given to establishing additional length increments. Consequently, the CCSB voted to withdraw the proposal to review and reassess the information of record and to consider the merits once again. History of Provisions Item 36010, applying on enameled steel products or wood covered with steel, was a rail adoption in 1936; attendant Note, item in its current form is a result of action taken on Docket 122, Subject 8 (January, 1966), and first appeared in Supplement 11 to NMFC A-9, effective July 20, Likewise, item 36020, applying on steel products or wood covered with steel, other than enameled, was also adopted from the rails in The current class 60 is a result of action taken on Special Docket No. 1 (issued July 20, 1949) and first appeared in NMFC A-1, effective July 10, Item was established for aluminum products 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 entry was amended as a result of Docket 59, Subject 64 (June, 1953) with the addition of the term aluminum, which appeared in Supplement 20 to NMFC A-1, effective February 16, The NOI was later added when item was established, as a result of action taken on Subject 31 of Docket 117 (January, 1965), first appearing in Supplement 13 to NMFC A-8, effective April 22, About Ceiling or Siding, Moldings, Panels or Ornaments Product offerings and options are as wide and varied as their applications. Panels, moldings and systems are available in a number of configurations and sizes to match the aesthetic and performance requirements of specific job installations. In this regard, acoustical 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 National Motor Freight Traffic Association, Inc. Subject 6, Page 3 of 7

4 panels may be required for sound control, attenuation or absorption; metal systems or pans with soft tones may be required for certain installations while other consistencies may be required for other uses; and geometric murals and other three-dimensional options are available for visual impact in creating scale, rhythm and ornamentation 2. Panels may be flat, curved or irregular. Applications include retail, hospitality, office, education, transportation and entertainment environments. Specific designs are available to counter an array of building issues, such as the need for moisture or mold resistance, abuse or fire resistance, seismic performance 3, or specialty applications. Some of the many product options are shown below. Geometric Panels Acoustical Ceiling Linear 3-D Suspension System Transportation Characteristics Density The information of record includes 1,194 figures on both aluminum and steel products, exhibiting a range in density from 1.07 to pcf, for an average density of pcf. The graph on the following page provides the frequency distribution of the overall range. 2 http// com/ceilings.html (accessed March 1, 2012) 3 Lateral and torsional stiffness-tested for earthquake prone areas. Subject 6, Page 4 of National Motor Freight Traffic Association, Inc.

5 20.0% Frequency Distribution 18.8% 19.6% % of Figures in Interval 15.0% 10.0% 5.0% 0.0% 0.0% 0.2% 3.1% 9.1% 12.4% 7.1% 10.7% 5.4% 13.6% Density Intervals (pcf) The graph shows a clustering of the figures, with density groups of less than 10 pcf, 10 but less than 22.5 pcf, and 22.5 pcf or greater. The table below provides a breakdown of the density figures according to the reported applicable NMFC item number. It should be noted that while the average densities for each item are different, the density ranges overlap and are quite wide. Item Material Construction Density Range (pcf) Average Density (pcf) Aluminum Enameled, iron or steel, or wood covered with iron or steel or tin plate Other than enameled, iron or steel, or wood covered with iron or steel or tin plate, nested or in panels Aluminum, acoustical ceiling, with or without insulating material When the data is evaluated based on the proposed density groupings, the following ranges and averages emerge. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater National Motor Freight Traffic Association, Inc. Subject 6, Page 5 of 7

6 Handling As previously mentioned, these commodities come in a multitude of sizes and shapes, with some units exceeding 96 inches in greatest dimension 4. (Some units exceed 192 inches in greatest dimension, but this does not appear to be typical; where greatest dimension is known, only 11 observations of record exceed 192 inches.) These commodities are packaged in fiberboard or wooden boxes. Generally, articles so tendered will not present any unusual or significant negative handling considerations. The larger, heavier units, however, can present handling difficulties even with the use of mechanical handling equipment. It should also be noted that in some instances shipments are labeled with precautionary markings or handling instructions, such as Fragile, Top Heavy, Use Extension Forks or This Side Up. Stowability Shipments of the involved ceiling or siding systems or components that do not exceed 96 inches in their greatest dimension should not pose any notable stowing problems 5. Stowing product shipments longer than 96 inches may prove to be more difficult than that of most general boxed freight. There are tangential issues as well, including the loss of vertical trailer space due to stacking prohibitions, and the requirement of floor-loading in many cases due to the size and configuration of shipments. Liability These commodities are not perishable, susceptible to theft or prone to spontaneous combustion or explosion. There is no evidence that they are unusually prone to be damaged, although some care and attention should be used to avoid cosmetic damage that may scratch, dent or blemish individual pieces. However, there is no indication of a significant claims problem. The value per pound, based on the limited value data available, ranges from $0.43 to $6.75, for an average of $3.59. Relationship to CCSB Policies and Guidelines CCSB policies call for replacing outdated terminology, combining descriptions embracing related commodities, eliminating excess or unclear wording and structuring item descriptions so as to foster clarification and simplification. At present, there are four separate listings for related commodities delineated by material construction, whether nested or in panels, whether acoustical or not, or whether with accompanying equipment or not. The information of record has shown that irrespective of construction, usage or form, the densities of articles embraced in all involved items overlap. Eliminating the present breakdown of provisions would improve the usability of the National Motor Freight Classification and promote simplification, consistent with CCSB policy. CCSB policies state that when commodities exhibit a wide range in densities, classes may be assigned based on density. The subject products range in density from 1.07 to pcf, with an average of pcf. CCSB policies also state that unusual or significant stowing, handling or liability characteristics may warrant deviation from the density guidelines. Classification precedent has been to assign a higher class than that usually associated with density when stowability, handling or liability is unusual or significant. When the greatest dimension does not exceed 96 inches, density appears to be the primary transportation 4 Item (Rule) 568, for Heavy or Bulky Freight, employs the threshold limit of exceeding 8 feet (96 inches) in greatest dimension as the measurement at which the consignor will perform the loading and the consignee will perform the unloading. 5 Product shipments are required to be in boxes with one exception, item 36020, which authorizes movements in packages. The proposed provisions would require shipments to be in boxes. Subject 6, Page 6 of National Motor Freight Traffic Association, Inc.

7 characteristic exhibited by the involved commodities. However, when the greatest dimension exceeds 96 inches, these commodities may be more difficult to handle and stow. The proposal would establish a new item with one set of classes predicated on density with breaks at 10 and 22.5 pcf for articles with greatest dimension not exceeding 96 inches, consistent with CCSB guidelines, as shown in the table below. It would assign a companion set of classes with the identical density groupings, but one class higher than that associated with the density guidelines for articles with greatest dimension exceeding 96 inches, as shown in the table 6. Density Group (pcf) Average Density in Group (pcf) Guideline Class When Greatest Dimension Does Not Exceed 96 CCSB Density Guideline (pcf) One Higher Than Guideline Class When Greatest Dimension Exceeds 96 Less than but less than or greater Concurrently, two new Notes would be established to clarify that the provisions also apply on geometric or three-dimensional (3-D) panels, and that the greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. This proposal is consistent with classification precedent. An example is Docket , Subject 9 (October, 2008), which involved blackboards, chalkboards, corkboards, tackboards, dry erase boards, markerboards or whiteboards, as named in item Density was shown to be the primary transportation characteristic when the greatest dimension did not exceed 96 inches. However, when the greatest dimension exceeded 96 inches, the involved products were shown to be more difficult to handle and stow. Accordingly, those products not exceeding 96 inches in greatest dimension were assigned density-based classes predicated on the CCSB s density guidelines, while products exceeding 96 inches in greatest dimension were assigned one class higher, respectively. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 6 Both sets of classes would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 6, Page 7 of 7