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

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1 Re: Grease Traps or Interceptors, plastic CCSB Contact: Matthew S. Erim Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item Articles, viz.: Articles, NOI; [Other Articles Listed Not Involved.] In boxes, crates, drums or Packages 870, 1078, 1241, 1273, 1456, 2195, 2212, 2213, 2230 or 2459, see Note, item , 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 Not Involved NOTE Not Involved NOTE Not Involved. THIS SPACE INTENTIONALLY LEFT BLANK 2015 National Motor Freight Traffic Association, Inc. Subject 10, Page 1 of 6

2 Present Classification Provisions Concluded PLUMBERS GOODS GROUP: subject to item Plumbers Goods, viz.: Plumbers Goods, NOI; [Other Articles Listed Not Involved.] In boxes or crates, 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 Not Involved NOTE Not Involved NOTE Not Involved. Proposed Classification Provisions CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item NEW Traps or Interceptors, grease, plastic, see Note, item 52581, in packages * NOTE Applies on devices designed to intercept greases, fats and oils before they enter a wastewater disposal system. PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item Articles, viz.: Articles, NOI; [Other Articles Listed No Change.] In boxes, crates, drums or Packages 870, 1078, 1241, 1273, 1456, 2195, 2212, 2213, 2230 or 2459, see Note, item , etc... No Change NOTE No Change NOTE No Change NOTE No Change. Subject 10, Page 2 of National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Concluded PLUMBERS GOODS GROUP: subject to item Plumbers Goods, viz.: Plumbers Goods, NOI; [Other Articles Listed No Change.] In boxes or crates, etc... No Change NOTE No Change NOTE No Change NOTE No Change. * Published in Supplement 5 to NMF 100-AO, issued on November 19, 2015 with an effective date of December 19, Analysis Research Project 1224 and Background of Proposal This proposal is based on information developed in connection with Research Project 1224, pertaining to grease traps or interceptors. The project was initiated in April 2014 in response to interpretative issues involving grease traps or interceptors, and information indicating transportation characteristics inconsistent with CCSB guidelines for the applicable classes. As part of the research, 86 potential manufacturers or shippers of grease traps or interceptors, and 11 associations believed to represent those companies, were sent questionnaires in April 2014, and for those that did not respond, again in June 2014 inviting them to participate in the research. An additional association was contacted as the CCSB was made aware of their potential interest. From those mailings, three companies responded that they do not manufacture or ship grease traps or interceptors, one company stated that they ship these commodities on their own fleet of trucks, and two companies provided information on metal grease traps or interceptors, but not on plastic. Of the associations contacted, two stated that they do not represent manufacturers or shippers of grease traps or interceptors, and one said they would forward the questionnaire to their members. No responses were received from the remaining associations. Subject 12 of Docket (September 2015) was a proposal to establish a specific item for grease traps or interceptors, with provisions based on the density of the handling unit as tendered to the carrier, as well as to make related changes to the descriptions of items and 52560, with no class change. An addendum to that proposal was prepared based on additional data received subsequent to the docketing of the proposal. Further evaluation of the data revealed that the material construction of these commodities has a significant impact on their transportation characteristics. In particular, it was found that metal products are typically more dense, with a wider range of densities, while plastic grease traps or interceptors are typically less dense, with a narrower range of densities. Acting on this information, the CCSB voted to modify that proposal by limiting the proposed provisions to 2015 National Motor Freight Traffic Association, Inc. Subject 10, Page 3 of 6

4 metal grease traps or interceptors, and to continue research on plastic grease traps or interceptors. The changes first appeared in Supplement 5 to NMF 100-AO, effective December 19, Currently, the NMFC does not provide a specific item for plastic grease traps or interceptors, and as such, these products have been found to be classified in items and , as shown in the Present Classification Provisions. About Grease Traps or Interceptors Grease traps or interceptors are plumbing devices installed in waste lines, which are designed to intercept most greases, fats and oils before they enter a wastewater disposal system 1. They can be made from a variety of materials such as plastic, iron, steel or concrete, and can range in size from small in-kitchen units to larger in-ground traps. Examples of plastic grease traps or interceptors are below. Transportation Characteristics Density The information of record on plastic grease traps or interceptors includes 30 density observations found during CCSB dock surveys and obtained from the CCSB s Density Study 2. The densities range from 2.58 to 6.38 pcf, with an average density of 3.93 pcf. The frequency distribution is shown on the following page. 1 (accessed November 2015) 2 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 10, Page 4 of National Motor Freight Traffic Association, Inc.

5 Frequency Distribution % of Figures in Interval 80.00% 60.00% 40.00% 20.00% 0.00% 63.33% 33.33% 0.00% 0.00% 3.33% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% Density Intervals (pcf) Handling and Stowability Plastic grease traps or interceptors are shipped in boxes secured to lift truck skids or pallets. Larger products may be shipped strapped on lift truck skids or pallets. There have been no reports of unusual or significant handling or stowability characteristics. Liability The involved products are not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor do they appear likely to damage other freight. Responding shippers and carriers indicate minimal to no claims on the involved products. No information was received on the value per pound of these commodities. Relationship to CCSB Policies and Guidelines CCSB policy calls for the establishment or amendment of classifications for commodities that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. There is no NMFC item that specifically names plastic grease traps or interceptors, creating interpretive issues. As such, to address this issue, it would be within CCSB policy to establish a new item under the Conduits, Other Than Earthen, Group for Traps or Interceptors, grease, plastic. CCSB policies also call for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. The information of record for plastic grease traps or interceptors shows these products have a density range from 2.58 to 6.38 pcf, with an average density of 3.93 pcf, and no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of 3.93 pcf is generally associated with class 250, which calls for a minimum average density of 3 pcf. Accordingly, this proposal would assign class 250 to the new item National Motor Freight Traffic Association, Inc. Subject 10, Page 5 of 6

6 Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and guidelines. Subject 10, Page 6 of National Motor Freight Traffic Association, Inc.