Staff Contact: Erin N. Topper Telephone (703) Item Description Class

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Leslie Egbert Craig
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1 Re: Fiber Optic Cable Staff Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class DRAWING INSTRUMENTS, OPTICAL GOODS OR SCIENTIFIC INSTRUMENTS: subject to item Cable, lightguide or lightwave, glass fiber, or Fiber Optic Cable, with plastic or metal sheathing, with or without one or more steel support strands, with or without necessary hardware, on reels, see Note, item 57771, or in boxes, see Notes, items and NOTE Cable may be shipped on reels provided that the last layer of cable is lagged or that the cable is wrapped between flanges extending full width of wound cable in one of the following methods: 1. With inch-thick solid fiberboard backed with 0.50-inch-thick foam plastic; 2. With a 160-pound minimum, high density polyethylene or polypropylene extruded plastic double-faced sheet having a ribbed or corrugated medium, backed with 0.25-inch foam plastic; 3. With solid thermoplastic material, with or without nonplastic fillers, inch minimum thickness, backed with a minimum thickness of inch of open or closed cell foam material; 4. With 4 millimeter high impact polypropylene fluted sheets, heat scored and sealed, having a density of 154 pounds per 1,000 square feet (MSF); 5. With three-layer laminated high density polyethylene board, having a density of 160 pounds per 1,000 square feet (MSF) with a total thickness of 4.3 millimeters, produced from one single-extruded facing, one double-extruded corrugated medium and one doubleextruded facing. All reels must be labeled with two precautionary markings indicating the proper handling procedure for such reels NOTE The provisions of Item 680, Sec. 1(a), Note 3, do not apply NOTE Provisions also apply on cable connectors, splice kits and necessary optical instruments to install cable when shipped with cable. Accessorial equipment not to exceed 15 percent of the weight upon which charges are assessed National Motor Freight Traffic Association, Inc. Subject 3, Page 1 of 7

2 Proposed Classification Provisions Item Description Class DRAWING INSTRUMENTS, OPTICAL GOODS OR SCIENTIFIC INSTRUMENTS: subject to item Cable, lightguide or lightwave, glass fiber, or Fiber Optic Cable, with plastic or metal sheathing, with or without one or more steel support strands, with or without necessary hardware, on reels, see Note, item 57771, or in boxes, see Notes, items and 57773: Sub 1 Cut to specified length, see Note, item NEW Sub 2 Other than cut to specified length as defined in Note, item NEW NOTE No Change NOTE No Change NOTE Also applies on cable connectors, splice kits and necessary optical instruments to install cable when shipped in same package with cable. NEW NOTE The term 'cut to specified length' embraces fiber optic cable which has been prepared for a specific installation when any damage to the cable will result in a claim for the entire length, and bills of lading and shipping orders are so notated. Shipping containers or packages must also be marked to indicate that any damage will result in a claim for the entire length of cable. Analysis Research Project 1120 Research Project 1120 was initiated in November of 2010 to determine if the current provisions of item 57770, naming fiber optic cable, are reflective of the products current transportation characteristics. During the course of the project, 304 potential shippers or manufacturers of fiber optic cable and 79 associations believed to represent those manufacturers or shippers were mailed questionnaires in February and April of Of those questionnaires sent, eight companies responded that they manufacture or ship these products, but only three of the eight responses contained useable information relating to shipments via less-than-truckload (LTL) motor carrier. Responses were received from 16 companies who are not involved in the manufacturing or shipping of fiber optic cable. Of the associations contacted, one association forwarded the questionnaire to its membership, while 26 associations responded that their memberships do not manufacture or ship these products. History of Provisions Item was established as a result of action taken on Docket 824, Subject 17 (May, 1982). The proposal originally sought to establish a class 85 for glass fiber lightwave cable. Based on the information from that record, the density ranged from to pcf (no average density was reported) and the value was $52.22 per pound (in 1982 dollars). The proposal also identified the less-than-favorable stowability associated with cable tendered on Subject 3, Page 2 of National Motor Freight Traffic Association, Inc.

reels, given that the reels, apparently tendered on the flanges, must be blocked and braced within the vehicle, and they could not be tiered.

These changes first appeared in Supplement 13 to NMF 100-I, effective January 29, 1983.

That change first appeared in Supplement 8 to NMF 100-Q, which became effective on March 30, 1991.

3 reels, given that the reels, apparently tendered on the flanges, must be blocked and braced within the vehicle, and they could not be tiered. The proposal was approved as modified by establishing the current class 100 and the three attendant Notes, items 57771, and These changes first appeared in Supplement 13 to NMF 100-I, effective January 29, As a result of action taken on Docket 911, Subject 9 (February, 1991) the specific term, fiber optic cable, was added to the item description, in the interest of clarification. That change first appeared in Supplement 8 to NMF 100-Q, which became effective on March 30, Except for amendments to packaging Note, item 57771, the item has remained substantially unchanged to the present. About Fiber Optic Cable Fiber optic cable is manufactured using strands of optically pure glass that is as thin as a human hair. The cable carries digital information for data communications and voice and video networks. Fiber optic cable is designed for indoor and outdoor applications, and the size and type of protective coating is reflective of the cable s intended use National Motor Freight Traffic Association, Inc. Subject 3, Page 3 of 7

4 Shipments of Fiber Optic Cable Subject 3, Page 4 of National Motor Freight Traffic Association, Inc.

% of Fiigures in Interval CCSB DOCKET 2012-1 Transportation Characteristics Density The information of record encompasses 1,102 density observations submitted by shippers and carriers, obtained

5 % of Fiigures in Interval CCSB DOCKET Transportation Characteristics Density The information of record encompasses 1,102 density observations submitted by shippers and carriers, obtained during CCSB dock surveys and culled from the CCSB s Density Study 1. The densities range from 1.56 to pcf, with an average density of pcf. The frequency distribution is below. Frequency Distribution 20% 16% 17% 17% 15% 10% 10% 12% 11% 12% 5% 0% 0% 1% 3% 2% Density Intervals (pcf) Handling and Stowability Based on the information of record, fiber optic cable is most often shipped on reels or in boxes on lift truck skids or pallets, as shown on page 4. When tendered in boxes on pallets, the cable should not present any unusual handling considerations, although extra care and attention may be required due to the fragile nature of the freight, as indicated by the Fragile and Handle With Care labels reportedly on some shipments. Additionally, based on the information submitted, fiber optic cable tendered in boxes on pallets may present some negative stowing considerations, as they may be marked Do Not Double Stack or bear instructions to the carriers not to breakdown the pallets. When tendered on reels, stowing and handling may be less favorable depending on the size and configuration of the reels as shipped. Reels may not provide a regular loadbearing surface, and reels not on pallets may require blocking and bracing (when oriented on flanges). Many reels contain precautionary markings or instructions such as Do Not Lay Reels Flat, Pick Up This Side Only, Do Not Remove From Cradle, Must Remain Upright, Do Not Stack, This Side Up, Use Load Bars, Secure/Lash to Wall, and Do Not Forklift Here. 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 3, Page 5 of 7

6 One member carrier reported that, due to the large number of claims they had several years ago on fiber optic cable, they implemented a program to instruct drivers and dockworkers to move and load the freight in the same orientation it is when tendered by the shipper. This program has proved to be effective in reducing damage claims for that particular carrier. Liability Fiber optic cable, particularly when cut to specified length and tendered on reels, is liable to damage. Cut to specified length means the cable has been prepared for a specific installation. Cable cut to specified length is subject to special damages, i.e. the potential liability increases greatly, as any damage to the cable will result in a claim for the entire length. Damaged fiber optic cable that is not cut to specified length will generally result in a claim for only the damaged section. Member carriers report that many shippers are not advising them at time of shipment, on shipping papers or on the packaging when fiber optic cable is cut to specified length; there are currently no such requirements in item When shipped on reels and not protected with rigid packaging material, fiber optic cable may be more susceptible to damage than when tendered in boxes or on reels covered with protective packaging material that complies with the requirements specified in Note, item Of the carrier reports received, none contained a claims ratio, but the carriers did indicate that the claims they have are high because any damage to the cable results in a claim for the entire length of cable shipped. Limited information on the value per pound indicates a range from $0.08 to $10.08, with an average of $3.57 per pound. One shipper reported that 90% of their shipments are made to order; however, they build in a tolerance by shipping 10% more cable than that ordered, at no additional charge to their customer. If part of the cable is damaged, but that portion can be cut off and the customer still has enough to complete the job, a claim will only be filed for the damaged portion. Even if the damaged portion is more than the required length, they will file for the portion damaged and, if they can, reuse the undamaged length of that shipment. However, if the cable has customer-specific print and the damage results in the cable being too short for its intended application, then a claim will be filed for a complete loss of the shipment. If a particular shipment may be subject to a claim for the entire length resulting from any damage to the cable, the shipper will notate it on the bill of lading. In the last year, the shipper has filed only one claim for a total loss. Relationship to CCSB Policies and Guidelines CCSB policies state existing classifications should be amended to reflect changes in transportation characteristics. Research Project 1120 was initiated to determine if the transportation characteristics of fiber optic cable have changed. The density of fiber optic cable ranges from 1.56 to pcf, with an average density of pcf. An average density of pcf is generally associated with the currently assigned class 100, per CCSB density guidelines, which call for a minimum average density of 9 pcf. Fiber optic cable is generally tendered on reels or in boxes on lift truck skids or pallets. Cable tendered in boxes on lift truck skids or pallets should not present any notable handling considerations, but as evidenced by precautionary markings on the handling units, some degree of care may be required due to the fragile nature of the product, and when stowing, the units should not be double-stacked. Cable tendered on reels may present additional Subject 3, Page 6 of National Motor Freight Traffic Association, Inc.

7 handling or stowing considerations, depending on the size and configuration as tendered for shipment. As detailed in the analysis, many reels are labeled with shipping instructions or precautionary markings on the proper handling and stowing of fiber optic cable. In this regard, a member carrier reports that they require their drivers and dockworkers to handle and stow the reels in the same orientation as they are tendered, which has reduced damage claims. Such measures are not typically required for general packaged freight. Fiber optic cable not cut to specified length will generally result in a claim for the damaged portion only. Fiber optic cable that is cut to specified length, on the other hand, has a much greater liability risk because if any portion of the cable is damaged, the carrier will be liable for the entire length. However, carriers report that shippers are not identifying fiber optic cable as cut to specified length on shipping papers or packaging. Item does not currently require such notations. Therefore, it would be in keeping with CCSB policies and precedent to amend item by adding two subprovisions. Sub 1 would apply on fiber optic cable cut to specified length at a class 175, and sub 2 would be applicable on cable, other than cut to specified length, at a class 100. The class 100 is consistent with the average density of pcf. The class 175 represents a four-class adjustment, reflective of the special damages associated with fiber optic cable cut to specified length. A similar approach was taken with brass, bronze or copper cable or wire. As a result of action taken on Docket , Subject 7 (February, 2010) former items 30920, 61160, and were canceled with reference to a new item, item 30310, with subprovisions based on whether or not the cable or wire is cut to specified length. A class 70, based on the average density, was assigned to cable or wire not cut to specified length, while a class 100, a four-class adjustment, was assigned to cable or wire cut to specified length. Concurrently, item 61150, naming aluminum electric cable, was amended to be structured with subprovisions based on whether or not the cable is cut to specified length, also with a fourclass differential. The changes first appeared in Supplement 1 to NMF 100-AJ, effective May 1, A new Note is proposed to be added to provide the definition of cut to specified length and to require shippers to give notice of the special nature of this freight to the carrier at time of shipment. Note, item allows for cable connectors, splice kits and necessary optical instruments to install cable when shipped with cable, but it is subject to a limitation that requires such equipment to not exceed 15 percent of the weight on which charges are assessed. In today s motor carrier environment, these restrictions are difficult to verify. Removing this restriction, as proposed, is in keeping with CCSB clarification policy National Motor Freight Traffic Association, Inc. Subject 3, Page 7 of 7

CCSB Contact: Erin N. Topper Telephone (703) Item Description Class

Re: Welding Bars, Rods or Wire (Welding Electrodes), iron or steel CCSB Contact: Erin N. Topper Telephone (703) 838-8856 topper@nmfta.org Proponent: Commodity Classification Standards Board Present Classification