CCSB Contact: William F. Mascaro Telephone (703) Item Description Class

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Rodger Richards
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1 Re: Radiator Cores CCSB Contact: William F. Mascaro Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Radiators, engine cooling: Sub 1 In boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 6 but less than Sub 4 12 or greater Sub 5 In packages other than boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 6 but less than Sub 8 12 or greater Radiator Cores, brass or copper, in boxes, crates or drums Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Radiators or Radiator Cores, engine cooling: Sub 1 In boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 6 but less than Sub 4 12 or greater Sub 5 In packages other than boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 6 but less than Sub 8 12 or greater Radiator Cores, brass or copper, etc... Cancel; see item National Motor Freight Traffic Association, Inc. Subject 14, Page 1 of 5

Analysis Research Project 1169 This proposal is based on information developed through Research Project 1169, which was initiated in October of 2012 to investigate the transportation characteristics

As part of the research, the CCSB mailed commodity questionnaires to 66 potential manufacturers or shippers and 11 trade associations believed to represent those manufacturers or shippers, inviting

2 Analysis Research Project 1169 This proposal is based on information developed through Research Project 1169, which was initiated in October of 2012 to investigate the transportation characteristics of radiator cores. As part of the research, the CCSB mailed commodity questionnaires to 66 potential manufacturers or shippers and 11 trade associations believed to represent those manufacturers or shippers, inviting them to participate in the research. The surveys were mailed in February of 2013, and again in June of 2013 to those that did not respond to the initial mailing. From this sampling, two associations indicated that they did not represent manufacturers or shippers of the involved articles. Six of the shipper questionnaires were returned as undeliverable, five companies responded that they did not manufacture or ship the involved articles, and five companies provided information. History of Provisions The provisions of item were adopted from the rail classification in A rating equivalent to the currently applicable class 85 first appeared in Supplement 1 to NMFC No. 4, with an effective date of July 10, The documentation for this change is no longer available, and the item has remained substantially unchanged to the present. About Radiator Cores Historically, a radiator core consisted of a series of channels or passageways designed to allow for the flow of fluid. The core was affixed to tanks on either side and the assembly was known as a radiator. Early radiator cores, as well as radiators, were generally made of brass or copper. To facilitate repair, the core could be removed from the side tanks and replaced. Over time, the materials used in the construction of a radiator core, as well as radiators, have changed to include plastic and aluminum, and the distinction between a radiator core and a radiator has become blurred as most modern engine-cooling radiators are one-piece units. The pictures below and on the following page depict products represented as radiator cores or radiators. As shown in the pictures, regardless of how they are represented, radiator cores and radiators are similar in nature. Radiator Cores Subject 14, Page 2 of National Motor Freight Traffic Association, Inc.

Radiators Transportation Characteristics Density In addition to the information developed through the CCSB questionnaire survey, the record also incorporates density observations from other sources,

Combined, these sources yield 2,377 density observations on articles reported to be moving under item 164790 as radiator cores, and result in a density range from 1.44 to 63.

00% 0.00% 0.04% 23.10% 20.36% 22.00% 16.66% 3.87% 4.12% 4.92% 2.65% 2.

3 Radiators Transportation Characteristics Density In addition to the information developed through the CCSB questionnaire survey, the record also incorporates density observations from other sources, including carrier-supplied data, CCSB dock surveys and the CCSB s Density Study 1. Combined, these sources yield 2,377 density observations on articles reported to be moving under item as radiator cores, and result in a density range from 1.44 to pcf, with an average density of 8.63 pcf. A frequency distribution of the overall density range is shown below. Frequency Distribution % of Figures in Interval 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 0.04% 23.10% 20.36% 22.00% 16.66% 3.87% 4.12% 4.92% 2.65% 2.27% Density Intervals 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 14, Page 3 of 5

4 The table below provides an evaluation of the density data on the basis of the currently applicable density breaks in item for engine-cooling radiators. Density Group Density Range Less than but less than or greater Handling and Stowability Radiator cores, like radiators, are generally tendered for shipment in fiberboard boxes that may be unitized on a lift truck skid or pallet, or tendered in crates. As with radiators, radiator cores shipped in boxes or crates should not pose any notable handling or stowability issues as they generally provide a flat load-bearing surface and are compatible with most other general boxed or crated freight. However, some radiator cores are shipped in reusable shipping racks, or banded on lift truck skids or pallets. Radiator cores tendered in this manner will generally not provide the same level of protection as when packaged in boxes or crates, and therefore, will require extra care and attention when handling and stowing to avoid damage. Radiator cores tendered in this manner may also lack a flat load-bearing surface for other freight. Liability The involved products are not perishable, nor are they prone to spontaneous combustion or explosion, and there is no indication that they are unusually susceptible to theft or likely to damage other freight with which transported. When tendered in boxes or crates, there is no indication that they are unusually susceptible to damage. However, when tendered in packages other than boxes or crates, they may be more prone to damage due to exposed surfaces. A limited amount of information on value shows a range from $2.13 to $9.92 per pound, with an average value of $5.53 per pound. There is no indication of a claims problem. 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. As previously detailed in this analysis, the materials used in the manufacture of radiator cores, like radiators, have changed to include plastic and aluminum, and the distinction between a radiator core and a radiator has become blurred as most modern engine-cooling radiators are one-piece units. Therefore, it would be in keeping with CCSB policy regarding clarification and simplification to cancel the provisions of item with reference to item and concurrently name Radiator Cores in item with Radiators. CCSB policy also calls for classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that articles described as radiator cores range in density from 1.44 to pcf, with an average density of 8.63 pcf. CCSB guidelines for the currently applicable class 85 in item call for a minimum average density of 12 pcf. CCSB policy further states that commodities or commodity groups exhibiting a wide density range not accurately reflected by a single overall average density may be assigned density-based classes. The following table relates the information of record to the density intervals in item and CCSB guidelines for the currently applicable classes Subject 14, Page 4 of National Motor Freight Traffic Association, Inc.

5 for engine-cooling radiators tendered in boxes or crates. As shown in the table, the average density identified for each density group is in keeping with CCSB guidelines for the applicable class. Density Group Current Class CCSB Minimum Guideline Less than but less than or greater However, CCSB policy also states that unusual or significant negative handling, stowability or liability characteristics may warrant deviation from the density guidelines. As with radiators, when radiator cores are tendered in boxes or crates, negative handling, stowability or liability considerations are greatly mitigated. Most boxes or crates provide a flat loadbearing 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. Negative handling, stowing and liability concerns have been found when radiator cores, like radiators, are tendered for shipment in packages other than boxes or crates. These packages generally do not provide a flat load-bearing surface, and may require additional attention when handling and stowing. They may impede the carrier s ability to safely load adjacent freight. Grouping radiator cores tendered in packages other than boxes or crates with like-packaged radiators would address the identified negative handling, stowability and liability considerations by providing the same one-class increase currently applicable to radiators, as shown in the table below. Density Group Average Density CCSB Minimum Guideline Class Based on CCSB Guidelines Class Adjustment Based on Handling, Stowability and Liability Considerations Less than but less than or greater Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent 2. 2 Precedent for this proposal may be found in Docket , Subject 4 (June 2009), which established the provisions of item , naming Radiators, engine cooling. The provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, National Motor Freight Traffic Association, Inc. Subject 14, Page 5 of 5

CCSB Contact: Shannon C. Allard Telephone (703) Item Description Class

Re: Mop Wringers and Buckets, Pails or Tanks combined, wheeled CCSB Contact: Shannon C. Allard Telephone (703) 838-1809 allard@nmfta.org Proponent: Commodity Classification Standards Board Present Classification