CCSB Contact: Matthew S. Erim Telephone (703) Item Description Class

Transcription

1 Re: Scaffolds, Scaffolding, or Scaffold Sections or Components CCSB Contact: Matthew S. Erim Telephone (703) Proponent: Safway Group LLC, Waukesha, Wisconsin Present Classification Provisions Item Description Class * Scaffolding or Scaffolds, or Components or Parts thereof, viz.: Builders or Maintenance Horses; Scaffolding or Scaffold Components or Parts, NOI; Scaffolding or Scaffolds, NOI; Scaffolding or Scaffolds, window cleaners ; In packages: Sub 1 Greatest dimension exceeding 192 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 2 Less than Sub 3 15 or greater Sub 4 Greatest dimension exceeding 96 inches but not exceeding 192 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 5 Less than Sub 6 15 or greater Sub 7 Greatest dimension not exceeding 96 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 8 Less than Sub 9 15 or greater * NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. * Published in Supplement 1 to NMF 100-AP, issued on March 17, 2016 with an effective date of April 16, National Motor Freight Traffic Association, Inc. Subject 1, Page 1 of 7

2 Proposed Classification Provisions Item Description Class Scaffolding or Scaffolds; Builders or Maintenance Horses; or Components or Parts thereof, viz.: Access Ladders; Access Stairs; Base Plates; Beams; Braces; Brackets; Casters; Clamps; Components or Parts, NOI; Frames; Gates, Gate Posts and Hinges; Guardrails; Planks; Posts; Screw Jacks; Starter Collars; Truss Bearers; Tubes; See Note, item NEW, in packages: Sub 1 Greatest dimension exceeding 192 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 2 Less than Sub 3 15 or greater Sub 4 Greatest dimension exceeding 96 inches but not exceeding 192 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 5 Less than Sub 6 15 or greater Sub 7 Greatest dimension exceeding 48 inches but not exceeding 96 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 8 Less than Sub 9 15 or greater Sub 10 Greatest dimension not exceeding 48 inches, see Note, item , subject to Item 170 and having a density in pounds per Sub 11 Less than Sub or greater Subject 1, Page 2 of National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Concluded Item Description Class NEW NOTE Applies on shipments of components or parts necessary to construct scaffolding, scaffolds or builders or maintenance horses, or on shipments of one or more of the named components or parts NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. Analysis This proposal was submitted by Safway Group LLC. The proponent believes that the provisions for scaffolding, as named in item , are not reflective of its products, as the bulk of their freight does not exceed 48 inches in length and has a density of 22.5 pcf or greater, while not possessing the same handling, stowability and liability issues that have been observed in scaffolding with greater dimensions. In addition, there are some potential interpretation issues related to the individual components or parts of a scaffolding system that are not specifically named in the description of item This proposal seeks to amend item by providing dimensional delineations which, the proponent believes, would produce more appropriate class assignments. A delineation would be established for articles with a greatest dimension not exceeding 48 inches, with a density break at 22.5 pcf. The current dimensional delineations, with density breaks at 15 pcf, would remain, for the most part, unchanged, except the delineation for greatest dimension not exceeding 96 inches would be limited to articles with a greatest dimension exceeding 48 inches but not exceeding 96 inches. Additionally, the description of item would be amended to name various scaffolding components or parts, and a new, clarifying Note would be added. History of Provisions Provisions for scaffolding were adopted from the rails in Since that time, numerous proposals have established and/or amended the provisions applying on scaffolding of different material construction and/or assembly 1. The current provisions were established as a result of action taken on Subject 2 of Docket (January 2016). That proposal canceled provisions applying on builders or maintenance horses, scaffolds, scaffolding or scaffold sections, as well as provisions for scaffold brackets, with reference to item , which had applied on so-called tube and clamp type scaffolding or scaffold components. Concurrently, item was amended to provide for the involved articles in a viz. format, with classes based on greatest dimension and density. That proposal was approved as docketed, and the changes first appeared in Supplement 1 to NMF 100-AP, effective April 16, For a more detailed history, see Subject 2 of Docket (January 2016) National Motor Freight Traffic Association, Inc. Subject 1, Page 3 of 7

4 About Scaffolding Scaffolding refers to a temporary structure used to support people and material in the construction, repair or maintenance of buildings and other large structures. It is usually a modular system of components which may include metal pipes or tubes and flooring material. The proponent s products are reported to be made of steel, with some aluminum components. Examples of the proponent s scaffolding, as tendered for shipment, are shown below. Transportation Characteristics Density The data furnished by the proponent yields 211 density figures ranging from 6.11 to pcf, with an average density of pcf. When the proponent s data is combined with CCSB data relating to these products 2, the information of record includes 12,779 density observations submitted by shippers and carriers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 3. Scaffolding ranges in density from 0.69 to pcf, with an average of pcf. 2 Obtained through Research Project 1208, which was the basis of CCSB Docket , Subject 2, and data submitted subsequent to that proposal. 3 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 1, Page 4 of National Motor Freight Traffic Association, Inc.

5 When the data is evaluated on the basis of the present density break at 15 pcf, which as proposed would be maintained where greatest dimension exceeds 48 inches, the following ranges and averages are calculated. Density Group Density Range Average Density Less than or greater When the data is evaluated on the basis of a density break at 22.5 pcf, as proposed where greatest dimension does not exceed 48 inches, the following ranges and averages are calculated. Density Group Density Range Average Density Less than or greater Handling Scaffolding is generally tendered uncovered or unprotected for shipment secured on lift truck skids or pallets with standing posts. Less commonly, scaffolding may be shipped in boxes secured on lift truck skids or pallets. Regardless of how they may or may not be packaged, the articles frequently overhang the lift truck skid or pallet, making handling more difficult. Packages may also be labeled with precautionary markings or handling instructions such as Fragile and Handle with Care. Scaffolding comes in a multitude of sizes and configurations. It is not uncommon for handling units to exhibit lengths over 96 inches, and lengths have been recorded up to 396 inches (33 feet). In such instances, safely handling units into and out of the vehicle becomes increasingly more difficult, and certain equipment, such as fork extensions, or additional personnel may be necessary to avoid damage to the scaffolding or other freight due to the presence of exposed or protruding edges. The level of difficulty increases as the length/size of the article increases, even if fork extensions are available and used. Often there is not enough room at carrier facilities to safely or easily handle and maneuver excessively long units. However, when the greatest dimension of a handling unit does not exceed 48 inches, many, if not all, of the unfavorable handling characteristics are greatly mitigated. When the greatest dimension does not exceed 48 inches, the article will generally not overhang a typical lift truck skid or pallet, and handling into and out of vehicles can be accomplished with no greater difficulty or hazard than other like-packaged freight. In this regard, where greatest dimension does not exceed 48 inches, the proponent s lift truck skids or pallets are often equipped with sides and ends, as shown in the photo on the right National Motor Freight Traffic Association, Inc. Subject 1, Page 5 of 7

6 Stowability Several negative stowing considerations have been identified. The lift truck skids or pallets are frequently not long enough to support the entire product, and having some degree of overhang is ordinary. Additionally, the handling units typically do not provide a flat load-bearing surface for top freight. On the previous record a carrier described the commodity as, too awkward [and] heavy to put on other freight. Furthermore, the presence of protruding edges inhibits the carrier s ability to safely load freight adjacent to the scaffolding. Excessively long handling units may further complicate the carrier s ability to structure a load and maximize vehicle utilization. Depending on the length/size of the article, the carrier will have to ensure that the freight will fit in the vehicle. When the greatest dimension of the handling unit does not exceed 48 inches, freight may be more safely and readily stowed adjacent to the scaffolding, particularly where the lift truck skid or pallet is equipped with sides and ends. However, the freight will still typically not provide a flat load-bearing surface, and only likepackaged freight may be stacked on top of the scaffolding, or some form of decking would have to be used. Liability Scaffolding is not perishable, hazardous in nature, or unusually susceptible to theft. Scaffolding tendered secured on lift truck skids or pallets with little or no protective packaging may have exposed edges or protrusions that can puncture, mar or otherwise damage adjacent freight, and it may also be susceptible to damage. Additionally, as reported on the previous record, one carrier indicated, when arriving at the consignee, often the scaffolding pieces are refused and returned to the shipper. We end up eating the cost of the commodity in a claim and selling the pieces for pennies on the dollar in salvage, while another carrier stated that the commodity is easily bent/damaged. The photo to the right, which was taken on a CCSB dock survey, shows a shipment of scaffolding piercing the packaging of adjacent freight. However, these concerns are greatly diminished when the greatest dimension of the article does not exceed 48 inches and does not overhang the lift truck skid or pallet, particularly where the lift truck skid or pallet is equipped with sides and ends. With regards to claims, the proponent reports that it filed five claims out of 14,376 shipments during a one-year period for a total of $12,914, and only one of those claims resulted from damage. Other information in the CCSB s files indicates zero to 24 claims annually, and claims ratios of 1.14% and 3.76% for two other shippers. Although not necessarily indicative of a claims problem, additional information in the CCSB s files indicates delivery exception rates of 6.66% and 9.09%. Value information furnished by the proponent ranges from $0.29 to $8.43 per pound, with an average value of $1.69 per pound. Overall, the value information of record ranges from $0.06 to $10.13 per pound, with an average value of $1.73 per pound. Subject 1, Page 6 of National Motor Freight Traffic Association, Inc.

7 Relationship to CCSB Policies and Guidelines This proposal seeks to amend item by altering the current provisions for scaffolding, which are predicated on greatest dimension and density. Where greatest dimension exceeds 48 inches, the current dimensional delineations would be retained, as would the current density breaks at 15 pcf, with no change to the assigned classes, reflective of the identified handling, stowability and liability considerations. The associated average densities, CCSB guidelines, guideline classes and assigned classes are depicted in the table below. Density Group Average Density CCSB Minimum Average Density Guideline Guideline Class Class Adjustment for Articles Exceeding 48 Inches but Not Exceeding 96 Inches Class Adjustment for Articles Exceeding 96 Inches but Not Exceeding 192 Inches Class Adjustment for Articles Exceeding 192 Inches Less than or greater This proposal seeks to add a delineation where greatest dimension does not exceed 48 inches. As asserted by the proponent, and as described in the analysis, scaffolding with a greatest dimension not exceeding 48 inches does not pose the same degree of unfavorable handling, stowability or liability characteristics as scaffolding with greater dimensions. The proponent proposes a density break at 22.5 pcf for articles not exceeding 48 inches in greatest dimension, with no class adjustment from the CCSB s guidelines, as depicted in the table below 4. Density Group Average Density CCSB Minimum Average Density Guideline Guideline and Proposed Class Less than or greater Concurrently, this proposal would amend the description of item to name specific scaffolding components or parts in the viz. listing, to prevent potential interpretation disputes. A new Note would also be added to clarify that this item applies on shipments of components or parts necessary to construct scaffolding, scaffolds or builders or maintenance horses, or on shipments of one or more of the named components or parts. 4 The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 1, Page 7 of 7