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

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1 Re: Pallets, Platforms, Skids or Shipping Racks, for lift trucks, steel or wood, with or without bodies, enclosures, ends, sides, stakes, standards or stacking posts Staff Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class HARDWARE GROUP: subject to item Skids, iron or steel, NOI LUMBER GROUP: subject to item Lumber, NOI; or Wood, built-up or combined, or Plywood, NOI; see Note, item , in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 12 but less than Sub 3 30 or greater NOTE Not Involved. PALLETS GROUP: subject to item Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, steel or wood, separate or combined: Sub 1 With bodies or enclosures of solid panel construction, SU, see Note, item Sub 2 With bodies or enclosures of other than solid panel construction, SU, see Note, item Sub 3 With standing sides, ends, stakes, standards or stacking posts, other than bodies or enclosures, see Note, item Sub 4 Without bodies, enclosures, ends, sides, stakes, standards or stacking posts; or with bodies, enclosures, ends, sides, stakes, standards or stacking posts, KD, folded or removed, and secured to base Sub 5 With standing sides, ends, stakes, standards or stacking posts, five or more units interlaced NOTE Also applies on equipment of interior packing forms, trays or devices when contained within the pallets, platforms or racks which they are intended to equip. WOODENWARE OR WOODEN ARTICLES GROUP: subject to item Skids, NOI National Motor Freight Traffic Association, Inc. Subject 10, Page 1 of 6

2 Proposed Classification Provisions Item Description Class HARDWARE GROUP: subject to item Skids, iron or steel, NOI, see Note, item A-NEW A-NEW NOTE Does not apply on steel Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, as named in item LUMBER GROUP: subject to item Lumber, NOI; or Wood, built-up or combined, or Plywood, NOI; see Notes, items and B-NEW, in packages, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 12 but less than Sub 3 30 or greater NOTE No Change. B-NEW NOTE Does not apply on wood Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, as named in item PALLETS GROUP: subject to item Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, steel or wood, with or without bodies, enclosures, ends, sides, stakes, standards or stacking posts, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE No Change. WOODENWARE OR WOODEN ARTICLES GROUP: subject to item Skids, NOI, see Note, item C-NEW C-NEW NOTE Does not apply on wood Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, as named in item Subject 10, Page 2 of National Motor Freight Traffic Association, Inc.

3 Analysis Research Project 1141 Research Project 1141 on steel or wood lift truck pallets, platforms, skids or shipping racks (hereinafter referred to as pallets ) was initiated in September, 2011 due to numerous interpretative inquiries regarding the current provisions of item In conjunction with the project, questionnaires were mailed to 347 potential shippers or manufacturers of pallets and eight associations believed to represent those shippers or manufacturers, in September and November of From those mailings, usable information was received from five companies; eight companies did not provide usable data; seven responded that they do not ship their products via less-than-truckload (LTL) motor carrier; and 14 reported that they do not ship or manufacture these products. Of the associations contacted, three responded. Two indicated that their membership is involved with the products, but did not provide information; one reported that they do not represent these shippers or manufacturers. History of Provisions The current classes and descriptions of subs 1 through 4 of item were established as a result of action taken on Docket 130, Subject 51 (September, 1967). That proposal was approved as docketed, and the provisions first appeared in NMFC A-10, effective July 1, The CCSB s historical files contain no information on the transportation characteristics considered on that proposal. As a result of action taken on Docket 755, Subject 42 (July, 1975), Note, item was established for clarification to resolve interpretation disputes. That proposal was approved as modified, and the change first appeared in Supplement 21 to NMF 100-B, effective February 13, The provisions for pallets with standing sides, ends, stakes, standards or stacking posts, five or more units interlaced, as named in sub 5, were added as a result of action taken on Docket 795, Subject 56 (July, 1979). That proposal was to assign a class reflective of the transportation characteristics of pallets tendered in this manner, and it was approved as modified. The provisions first appeared in Supplement 17 to NMF 100- F, effective March 1, 1980, and the item has remained substantially unchanged to the present. About Lift Truck Pallets, Platforms, Skids or Shipping Racks The dictionary 1 defines a pallet as a small, low, portable platform on which goods are placed for storage or moving, as in a warehouse or vehicle. Pallet sizes and constructions first became standardized by the brick industry in 1945 and then by the food industry in Today, the National Wooden Pallet and Container Association 2 (NWPCA) maintains the Uniform Standard for Wood Pallets. Despite the standardization, pallets are often customized for their particular use in order to ensure the pallet s integrity is appropriate for the load it bears. Pallets may provide two-, four- or even eight-way entry; be designed for single trips or reuse; have sides, stacking posts or enclosures; be nestable or stackable; or have special markings. 1 (Accessed May 19, 2011) 2 (Accessed May 19, 2011) 2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 3 of 6

4 As shown in the photos below, there is a wide variety of types, sizes and styles of steel or wood lift truck pallets, platforms, skids or shipping racks. In the 1980s there was a distinct difference between skids and pallets. In a 1987 reference book 3, the definition of a pallet was a low, portable platform of wood, plastic, metal, fiberboard or combinations thereof, to facilitate handling, stowage and transportation of materials as a unit. The same book defined a skid as one of a pair or series of parallel wood runners affixed to the under side of boxes, crates, etc., to allow entry of platform truck or truck forks. Timbers, bars, rails, or the like, used in pairs or sets, to form a slideway or rollway, as for an incline to a sidewalk, or such a set fastened to the bottom of a machine or structure to 3 Packaging Institute International, The. Glossary of Packaging Terms. Sixth Edition. Stamford, Subject 10, Page 4 of National Motor Freight Traffic Association, Inc.

5 % of Figures in Interval CCSB DOCKET facilitate sliding. Information found on current websites state the definition of a skid is a pallet having no bottom deck 4. Over time, the terms lift truck skids and pallets have become synonymous within the packaging and shipping industries. Therefore, it has been found that some shippers may be misclassifying their pallets under item for iron or steel skids, NOI, or item for wood skids, NOI. Additionally, it has been reported that item , which names wood, built-up or combined, has also been misapplied to wood pallets. Transportation Characteristics Density The information of record includes 1,953 density observations submitted by shippers and carriers, obtained during CCSB dock surveys and culled from the CCSB s Density Study 5. The densities range from 1.05 to pcf, with an average of pcf. The frequency distribution below shows the data is distributed throughout the range. Frequency Distribution 20% 15% 10% 6% 16% 17% 17% 10% 14% 11% 5% 0% 0% 2% 3% 3% Density Intervals (pcf) Handling Pallets will be readily handled with mechanical equipment and should not pose any unusual or significant handling considerations. 4 (Accessed May 19, 2011) 5 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 10, Page 5 of 6

6 Stowability Pallets without standing sides, ends, stakes, standards or stacking posts, or with bodies or enclosures, tendered loose or banded together, should be stackable upon themselves and provide a flat load-bearing surface for other freight. Pallets with standing sides, ends, stakes, standards or stacking posts may or may not provide a flat load-bearing surface and may or may not be stackable upon themselves, but no unusual or significant stowing considerations have been reported. Liability Pallets are not unusually susceptible to theft or liable to damage and should not damage freight with which stowed. One carrier reported a claims ratio of 0.12%, indicating there is not a significant claims problem. The value per pound ranges from $0.07 to $4.71, with an average of $1.89 per pound. Relationship to CCSB Policies and Guidelines CCSB policies call for the amendment of existing classifications that are a source, or potential source, of interpretation disputes and to reflect changes in transportation characteristics. The information of record includes 1,953 density observations that range from 1.05 to pcf, with an average of pcf. CCSB policies state that when commodities exhibit a wide range in density that is not accurately reflected by a single class, density-based provisions may be established, especially when there are no unusual or significant stowability, handling or liability concerns. And when the densities are distributed throughout the range and a substantial percentage of the figures exceed 20 pcf, classes based on the CCSB s standard 11-subprovision density scale may be assigned. Amending item to apply on steel or wood lift truck pallets, platforms, skids or shipping racks, with or without bodies, enclosures, ends, sides, stakes, standards or stacking posts, with classes based on the CCSB s 11-subprovision density scale 6, as proposed, is in keeping with CCSB policy and precedent. Such an approach was taken on Docket , Subject 4 (January, 2011), involving item 61700, naming electrical appliances or instruments, NOI. That was a proposal to establish the 11-subprovision density scale within the Electrical Equipment Group for the involved commodities. Information on that record included 30,522 density observations ranging from 1.00 to pcf, with a simple average density of 9.58 pcf, a substantial percentage of figures exceeding 20 pcf, and no unusual or significant stowability, handling or liability considerations. Action on that proposal was deferred to Docket (May, 2011) when it was approved as docketed. The amended provisions first appeared in Supplement 2 to NMF 100-AK, effective July 23, Concurrently, it would be in keeping with CCSB policies to add attendant Notes to items 96760, and to clarify that those provisions do not apply on pallets, as named in item This proposal, as docketed, is in keeping with CCSB policies and precedent. 6 The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 10, Page 6 of National Motor Freight Traffic Association, Inc.