It is proposed to amend Item (Rule) 181, Furniture Package Performance Testing, as follows: FURNITURE PACKAGE PERFORMANCE TESTING

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1 Re: Item (Rule) 181, Furniture Package Performance Testing Staff Contact: Erin N. Topper Telephone (703) Proponent: Smurfit-Stone Container Corporation s Package Performance Test Lab, Inc., Carol Stream, Illinois Proposed Classification Provisions It is proposed to amend Item (Rule) 181, Furniture Package Performance Testing, as follows: ITEM 181 FURNITURE PACKAGE PERFORMANCE TESTING Introduction No Change. Section I. Conditioning Except as provided in Note NEW, all specimens must be conditioned in an atmosphere of 73 F (23 C) minimum and 50% RH minimum for at least 24 hours. Testing should be conducted in the same minimum atmosphere, and conditions must be recorded for each test conducted. If testing cannot be conducted in the minimum atmosphere, conduct the tests as soon as possible after the packaged products have been stored for 24 hours in the testing environment. NOTE NEW1 Alternatively, fiberboard packaging may be conditioned in an atmosphere of 40 F (4 C) and 85% RH or 100 F (38 C) and 85% RH for at least 72 hours. Section II. Compression/Vibration Test Two alternative methods are permissible, Method (A) or (B). If the container is 6 ft (1.83 m) or taller in height, and has either a skid or pallet outside base or is marked with upright arrows, the compressive load requirements in Methods (A) and (B) may be omitted. Method (A) (1) Shipping units must be vibration tested under a stacked, nonresponsive compressive load for twenty minutes one hour on three axes using the procedures of ASTM D4169 Schedule D, Assurance Level II, for random vibration on each of the three planes (regardless if the shipping container has upright arrows printed on the package) for a total of three hours. If the shipping container has a skid or pallet outside base then Face 3 should be vibrated down for a total length of time of three hours. When conducting top load vibration tests, the size of the package changes with the three planes of the package, so the dead load weights on the top of the package will change accordingly: Face 3 is the bottom of the package; Face 4 is the length of the package (wide side); and Face 6 is the width of the package (narrow side). 1 Subsequent Notes in Item 181 would be renumbered as necessary. Subject 2, Page 1 of 5

2 Proposed Classification Provisions Continued The exception to this procedure: Shipping units clearly marked on at least two panels of the container with UP arrows require concentrated dead load to be applied only in the axis (axes) indicated by the UP arrow orientation. The vibration test must be performed on all three axes. (2) Use a concentrated dead load (see description of load following formula) to simulate miscellaneous freight loaded on top of a floor-stowed shipping unit in a trailer of 108 in (2.7 m) inside height. Determine the amount of load, rounded to the nearest pound force (lbf), for each axis of test from the formulas in Table 1: Table 1: Method (A) Force Calculation Orientation Face 3 Down: 10 x (108 h) x (l x w) x 5 FORCE = Orientation Face 4 Down: 10 x (108 w) x (l x h) FORCE = Orientation Face 6 Down: 10 x (108 l) x (w x h) FORCE = Where: FORCE = pounds of force (lbf) average density of LTL 10 = freight (pcf) inside height of trailer (in), 108 = see Note 1 = conversion from in3 to ft3 height of shipping unit in the h= length of shipping unit in the l= width of shipping unit in the w= 5 = Design Factor (DF) (a) The concentrated dead load, see Notes 2 and 3, shall consist of: 1. Dead load container(s). 2. Plywood sheet(s) must be larger than test specimen's top dimension. (b) No Change. NOTE 1 No Change. NOTE 2 Cancel; no further application. NOTE 3 No Change. Subject 2, Page 2 of 5

3 Proposed Classification Provisions Concluded Method (B) Shipping units must be subjected to compression and vibration in separate tests. A compression test is conducted first, and then the same shipping unit is vibration tested. (1) Conduct a compression test on the shipping unit, using either a machine compression test (per ASTM D642) or a constant load (dead weight) test (see Notes 5, 6 and 7). Apply a force as calculated from the formula in Table 2, rounded to the nearest pound force (lbf), on each of the three planes (regardless if the shipping container has upright arrows printed on the package) for a total of three hours. If the shipping container has a skid or pallet outside base then Face 3 should be vibrated down for a total of three hours. in each of the three axes (exception as in Method (A) stating that shipping units clearly marked on at least two panels of the container with UP arrows requires compression to be applied only in the axis (axes) indicated by the UP arrow orientation) as calculated from the formula in Table 2: Table 2: Method (B) Force Calculation FORCE = Where: 10 x (108 h) x (l x w) x 5 FORCE = pounds of force (lbf) average density of LTL freight 10 = (pcf) inside height of trailer (in), see 108 = Note 4 = conversion from in3 to ft3 height of shipping unit in the h= length of shipping unit in the l= width of shipping unit in the w= 5 = Design Factor NOTE 4 No Change. NOTE 5 Cancel; no further application. NOTES 6-7 No Change. (2) Using the same shipping unit, without applying any compression force or load, conduct a vibration test for twenty minutes one hour in each of the three axes planes for a total of one hour three hours as defined earlier within the section. Any of the three following vibration methods may be used: (a) Random, ASTM D4169 Schedule E Level II (b) Repetitive shock, ASTM D4169 Schedule F (vertical-linear motion) (c) Repetitive shock, ASTM D4169 Schedule F (rotary motion) Sections III-VI No Change. Subject 2, Page 3 of 5

4 Analysis This proposal was submitted by Smurfit-Stone Container Enterprises, Inc., a CCSBregistered package testing laboratory. Based on experience and an understanding of the dynamics of the motor carrier environment, the proponent has proposed to amend portions of Sections I and II of Item (Rule) 181. Section I, Conditioning, currently states that packages must be conditioned in ambient conditions of 73 degrees Fahrenheit and 50% relative humidity (RH) for at least 24 hours. It is proposed to allow fiberboard packages to be conditioned at varying temperatures for 72 hours prior to testing. These conditions are 40 degrees Fahrenheit and 85% relative humidity or 100 degrees Fahrenheit and 85% relative humidity. This change would make the conditioning requirements consistent with ASTM D4332, Standard Practice for Conditioning Containers, Packages, or Packaging Components for Testing. Section II of Item 181, Compression/Vibration Test, does not contain the same safety disclaimer regarding the compressive load requirements that is currently in Item 180. For consistency, both rules should have the same basic safety criteria named. The compression and vibration testing has two methods, Methods A and B. Method A subjects the packages to vibration testing under a stacked, nonresponsive compressive load in accordance with ASTM D4169 Schedule D, Assurance Level II, for a total of one hour (20 minutes in each of the three planes). The planes are identified by the face of the package. Face 3 is the bottom of the package; Face 4 is the length of the package (wide side); and Face 6 is the width of the package (narrow side). Currently, the procedure requires the same load to be used on all three faces during top load vibration tests, even though the size of the package changes. Based on sample testing, the proponent found that if the load formula was not changed to reflect the differences in the package s size when conducting testing on Faces 6 or 4, Face 6 would experience a 41% larger load and Face 4 would experience a 24.6% larger load. For Methods A and B, it is also proposed to amend the duration of the vibration testing from a total of one hour (20 minutes per plane) to three hours (one hour per plane), in order to be consistent with other truck-related vibration test procedures. Additionally, there is no established rounding increment listed for the required force, and one should be established to prevent any miscalculation. The rounding increment should be one pound force (lbf). The formulas to calculate force in Methods A and B contain a Design Factor (DF) of 5. However, it has been found that the Design Factor in the formula may prevent the package from being tested, because it exceeds the maximum gross weight of the vibration table, since most vibration tables cannot handle gross payloads over 3,000 pounds. Not to mention the safety issues associated with putting that much weight on top of a package. Also, in a review of earlier versions of Item 181 it was found that the formula did not originally contain this Design Factor. In an effort to account for the high force calculations when including the Design Factor, Notes 2 and 5 were added to the procedure and limit the amount of force to 750 pounds. By removing the DF of 5, this limitation would not be necessary since most vibration tables would be able to handle the actual calculated force. Subject 2, Page 4 of 5

5 History Due to the chronic damage problems that exist with the handling of furniture in the LTL environment, Item (Rule) 181 was established to test the performance of packages for furniture and furniture parts. It provides an alternative to the packaging provisions found within the Furniture Group, item 79000, and the Furniture Parts Group, item 82750, the numbered F and S packages, Item (Rule) 180 and the Test Shipment Permit Program. The rule first appeared in Supplement 5 to NMF 100-Z, effective July 22, 2000, as a result of action taken on Subject 19 of Docket (May, 2000), which was approved as docketed. Based on information developed during Research Project 1034, the CCSB docketed a proposal, Docket , Subject 16 (October, 2009), to amend the rule in the interest of clarification and simplification. That proposal was approved as docketed, and the changes became effective on January 9, As part of that proposal, it was stated that, going forward, the CCSB would amend the rule, as needed, on a case-by-case basis to ensure it continues to be representative of the motor carrier environment. Relationship to CCSB Policies and Guidelines One of the best ways to determine if packaging is capable of sufficiently protecting the commodities being shipped is through laboratory testing, which accounts for the dynamics of the transportation environment. Package testing is continuously changing and improving based on research from many different sources. The proponent is an active CCSB-registered third party testing laboratory, and as such, has vast experience with numerous testing protocols. CCSB policies state the Classification s rules must be kept up-to-date. Based on other truck-related testing procedures and the proponent s knowledge and experience in the industry, the proposed changes to Sections I and II of Item 181 will improve the procedure while making it more consistent with other established testing procedures for the motor carrier environment. For these reasons, the proposal, as docketed, is in keeping with CCSB policies. Subject 2, Page 5 of 5