DOCKET SEPTEMBER 2013

Transcription

1 DOCKET SEPTEMBER 2013 A public meeting on National Motor Freight Classification provisions will be held on September 23, 2013 at: Hilton Alexandria Old Town 1767 King Street Alexandria, Virginia ISSUED: August 8, 2013

2 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET On Monday, September 23, 2013, the Commodity Classification Standards Board (CCSB) will conduct a public meeting to consider proposals for amending the National Motor Freight Classification (NMFC ). The meeting will be held at the Hilton Alexandria Old Town, 1767 King Street, Alexandria, Virginia 22314, commencing at 2:00 pm. Section I of this docket provides the CCSB analyses for proposed amendments that will be considered at the meeting. Each analysis includes the full text of the proposal, the CCSB contact and the identity of the proponent. Section II of this docket provides notice of proposed amendment of the CCSB s Value Guidelines, which the CCSB will consider at the meeting on September 23, The proposed valuation adjustments are shown. Section III of this docket provides notice of classification changes made necessary by law, by order of a regulatory body or for clarification. The symbol indicates a proposed classification change. The symbol indicates that the commodities may be subject to federal regulations concerning the shipping of hazardous materials. The symbol indicates a registered trade name or registered trademark. The symbol indicates a trademark. Public Docket Files Supporting data and other relevant information pertaining to each proposal in Section I herein, including how to contact the proponent, are contained in a Public Docket File. The public files are available online without charge at They are organized by docket and subject numbers, and each file is indexed for ease of reference. Interested persons who do not have Internet access can obtain the public docket file for a particular proposal from the CCSB contact, subject to a charge for copying and transmitting the document(s) requested. Commodity Classification Standards Board ccsb@nmfta.org Chairman Joel L. Ringer Member George M. Beck Member Daniel E. Horning Member William F. Mascaro Member Donald A. Newell Packaging and Classification Consultant Erin N. Topper Counsel John R. Bagileo Page i

3 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET The Commodity Classification Standards Board invites all interested persons to participate in the classification process. Anyone having an interest in a proposal listed in this docket is welcome to attend the meeting and/or submit a statement relating to the transportation characteristics of the product(s) involved or relevant to packaging materials or methods in connection with proposed packaging amendments. Statements should include any underlying studies, supporting data and other pertinent information. Written submissions will be included in the respective public docket file. Decisions on docketed proposals will be based on the information contained in the public docket file. Any person may become a Party of Record to a docketed proposal by submitting a written request prior to the meeting. The proponent(s) of a proposal and anyone who attends the meeting in connection with a proposal or submits a written statement prior to the meeting will be registered as a party of record to that proposal. Parties of record to a docketed proposal will receive a disposition of the proposal and will be entitled to seek reconsideration or arbitration should they disagree with that disposition. (One does not have to be a party of record to request reconsideration.) Our address is: Commodity Classification Standards Board, 1001 North Fairfax Street, Suite 600, Alexandria, Virginia 22314, and our fax number is: Written statements may also be ed to the CCSB contact involved. To schedule an appearance at the meeting, or if you require further information, please get in touch with the CCSB contact. Anyone requesting assistance in accordance with the Americans with Disabilities Act will be accommodated. The CCSB s policies and procedures as well as other information on the CCSB and the National Motor Freight Traffic Association are available online at Amendments to the National Motor Freight Classification resulting from the proposals in this docket will be published in a supplement to the NMFC, unless reconsideration is granted or arbitration is sought in accordance with the CCSB s rules. The supplement is scheduled to be issued on November 14, 2013, with an effective date of December 14, Future CCSB Dockets Docket Docket Docket Closing Date November 14, 2013 March 13, 2014 Docket Issue Date December 12, 2013 April 3, 2014 CCSB Meeting Date January 28, 2014 May 20, 2014 Dates are as currently scheduled and subject to change. For up-to-date information, go to Page ii

4 COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET INDEX OF SUBJECTS (PROPOSALS) DESCRIPTION SUBJECT DESCRIPTION SUBJECT B Baby Carriers, front-pack, including Slings or Wraps Base Cabinets (Work Bases)... 4 Binnacles or Binnacle Hoods Booths, telephone, wooden Broilers, cooking, portable, outdoor type, ceramic... 8 C Cabinets, base (Work Bases)... 4 Cabinets, fire hose or fire extinguisher storage... 7 Cabinets, kitchen or bathroom... 4 Cabinets, sink or stove... 4 Cabinets, storage or wardrobe, NOI... 4 Carriers, baby, front-pack, including Slings or Wraps D Determination of Density Item (Rule) 110, Sec Dryers (Drying Machines), household Packaging... 3 E Earphones... 6 F Flashlights, electric, hand held, with power supply cord Flat Glass... 1 G Glass, flat... 1 Golf Club Heads or Shafts, wooden, unfinished Grills, cooking, portable, outdoor type, ceramic... 8 H Headphones or Headsets... 6 Heads, golf club, wooden, unfinished Hoods, binnacle I Item (Rule) 110, Sec. 8, Determination of Density... 5 Item (Rule) 181, Furniture Package Performance Testing Item (Rule) 680, Secs. 1(a), 5 and 10(a), Packing or Packaging General L Lockers, storage or wardrobe, NOI... 4 Lumber, cigar box P Packaging Dryers (Drying Machines), household... 3 Packaging Furniture Package Performance Testing Packaging Washers (Washing Machines), household... 2 Packing or Packaging General R Roasters, cooking, portable, outdoor type, ceramic... 8 S Searchlights, electric, hand held, with power supply cord Shafts, golf club, wooden, unfinished Skateboards... 9 Smokers, cooking, portable, outdoor type, ceramic... 8 Spotlights, electric, hand held, with power supply cord W Washers (Washing Machines), household Packaging... 2 Page iii

5 SUBJECT 1 Re: Flat Glass Item CCSB Contact: Daniel E. Horning Telephone (703) horning@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class GLASS: subject to item Glass, flat, NOI, see Note, item 86701: Sub 1 Bent, in boxes or crates: Sub united inches or less Sub 3 Exceeding 220 united inches but not exceeding 15 feet in length nor 9 feet in width Sub 4 Exceeding 15 feet in length or 9 feet in width Sub 5 Not bent, see Note, item 86702, in boxes, crates or Packages 195, 198, 235, 785, 2008, 2025, 2147, 2149, 2160, 2239, 2245, 2281 or 2497: Sub united inches or less Sub 7 Exceeding 220 united inches but not exceeding 15 feet in length nor 9 feet in width Sub 8 Exceeding 15 feet in length or 9 feet in width NOTE The term flat applies to glass known as sheet, plate, polished prism, rolled, window or float glass, whether or not polished, laminated, colored, opalescent, opaque, chipped, decorated, wired, etched, figured, acid dipped, ground, sandblasted, metalized (sprayed with atomized metal while glass is hot) or tempered, but not when silvered for mirrors, nor flashed, nor framed or leaded (set in or framed by lead or other metal) NOTE Flat glass, not bent, may also be cut to size, edges beveled or ground, or holes cut or drilled. THIS SPACE INTENTIONALLY LEFT BLANK Subject 1, Page 1 of 8

6 SUBJECT 1 Proposed Classification Provisions Item Description Class GLASS: subject to item Glass, flat, bent or not bent, NOI, see Notes, items and 86702, in boxes, crates or Packages 195, 198, 235, 785, 2008, 2025, 2147, 2149, 2160, 2239, 2245, 2281 or 2497: Sub 1 Greatest dimension exceeding 96 inches, see Note, item NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 8 but less than Sub 4 12 or greater Sub 5 Greatest dimension not exceeding 96 inches, see Note, item NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 8 but less than Sub 8 12 or greater NOTE No Change NOTE No Change. NEW Analysis NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. Research Project 1165 Research Project 1165 was initiated in July 2012 in response to reports that shipments of flat glass exhibited densities inconsistent with the provisions of item Item currently provides for glass either bent or not bent, subject to one of six classes, with final determination predicated on the size of the glass. During the project, questionnaires were sent to 74 potential manufacturers or shippers and 13 trade associations related to the glass industry. Mailings were sent in October 2012, and for non-respondents, a second, follow-up letter was sent in December From those mailings, two companies responded with usable information; three firms did not provide usable data; one responded that they do not manufacture or ship flat glass, and one questionnaire went unclaimed. Of the associations contacted, five responded, indicating that they do not represent manufacturers or shippers of flat glass. Additional information was developed through CCSB dock surveys and carrier-submitted reports. History of Provisions The original provisions for flat glass were adopted from the rails in 1936 and first appeared in LTL-1. The provisions have been amended over the years. The last significant change occurred as a result of action taken on Subject 39 of Docket 120 (September 1965), Subject 1, Page 2 of 8

7 SUBJECT 1 which established the present alignment and classes. The change first appeared in Supplement 13 to NMFC A-9, effective September 27, About Flat Glass As per the Note, item 86701, the term flat applies to glass known as sheet, plate, polished prism, rolled, window or float glass, whether or not polished, laminated, colored, opalescent, opaque, chipped, decorated, wired, etched, figured, acid dipped, ground, sandblasted, metalized (sprayed with atomized metal while glass is hot) or tempered, but not when silvered for mirrors, nor flashed, nor framed or leaded (set in or framed by lead or other metal). Shipments of Flat Glass Among the many precautionary warnings affixed to glass shipments is the restriction that glass is not to be laid flat. As a consequence, most, if not all forms are mounted on edge, vertically oriented, and in most cases, supported by outriggers in an A-frame configuration or something similar. This applies whether the glass is bent or not. Alternatively, some shipments have been observed in crates. Various depictions are provided below and on the following page. Subject 1, Page 3 of 8

8 SUBJECT 1 Transportation Characteristics Density The information of record includes 336 density figures ranging from 1.11 to pcf, with an average density of 7.99 pcf. As depicted in the following graph, the densities are distributed throughout the range. However, the data can be divided into three density groupings of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater. Frequency Distribution % of Figures in Interval 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 3.57% 0.00% 21.73% 23.21% 17.86% 8.93% 7.74% 7.74% 6.25% 1.49% 1.49% Density Intervals (pcf) Flat glass shipments with greatest dimension not exceeding 96 inches have an average density of 8.43 pcf, with a range of 1.11 to pcf, as depicted in the frequency distribution on the following page. Subject 1, Page 4 of 8

9 SUBJECT 1 Greatest Dimension Not Exceeding 96" % of Figures in Interval 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 23.98% 18.70% 18.29% 9.35% 8.54% 9.35% 6.10% 0.00% 2.44% 1.22% 2.03% Density Intervals (pcf) The following table shows the data for flat glass having greatest dimension not exceeding 96 inches when it is evaluated with two density breaks at 8 and 12 pcf. Density Group Density Range (pcf) Average Density (pcf) Less than but less than or greater Flat glass shipments with greatest dimension exceeding 96 inches range in density from 1.14 to pcf, for an average density of 6.76 pcf, as illustrated in the following graph. Greatest Dimension Exceeding 96" % of Figures in Interval 30.00% 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 6.67% 30.00% 21.11% 16.67% 7.78% 5.56% 3.33% 6.67% 2.22% 0.00% Density Intervals (pcf) Subject 1, Page 5 of 8

10 SUBJECT 1 The table below shows the data for flat glass having greatest dimension exceeding 96 inches when it is evaluated with two density breaks at 8 and 12 pcf. Density Group Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling Flat glass is inherently fragile and therefore requires due diligence and special attention in vehicle loading, unloading and in cross-docking procedures. Shipments are often labeled or marked with directional arrows and other handling instructions such as Fragile, Handle With Care, Keep Braced At All Times, Case Must Remain on Pallet, This Side Up, Do Not Lean or Lay Flat, among others 1. Flat glass exceeding 96 inches in greatest dimension presents additional considerations for the carrier 2. As greatest dimension increases, the handling into and out of the vehicle, and cross-dock operations, become considerably more difficult, and certain equipment, or additional personnel, may be necessary to safely handle the freight. Stowability Product shipments are packaged in a variety of forms but are generally tendered vertically oriented, on edge in some kind of A-frame or rack structure (when not in crates or wooden cases or boxes), and are usually supported by outriggers or customized bracing. Due to the configuration and size of the handling units, carriers are generally restricted to floor loading, and may have difficulty loading other goods around these commodities as the units typically do not provide lateral support for adjacent freight. Due to the specific nature of glass and restrictions on double stacking or loading other freight on top, carriers are prevented from utilizing all available vehicle space. Flat glass exceeding 96 inches in greatest dimension presents additional difficulties for the carrier in structuring a vehicle load. Liability Glass is not perishable, prone to spontaneous combustion or explosion or unusually susceptible to theft. A limited amount of information available on the value of the involved glass indicates a range from $0.10 to $5.69 per pound, with an average value of $3.04 per pound. Carrier claims personnel were contacted, and while no information was submitted that would indicate an unusual or significant damage problem, flat glass may be more susceptible to damage than other types of general freight due to its inherent fragility. This potential has long been recognized in the NMFC through more explicit packaging requirements and handling instructions. In this regard, Note, item 86512, governing the Glass generic heading, states in part, shipments must be so packed and so loaded that glass rests on full flat edge. Glass, other than tempered, when shipped in containers other than those requiring mechanical handling equipment, must be conspicuously marked on two flat sides as follows. 1 Other labels that have been observed include Glass Do Not Drop, Do Not Double Stack, Keep Dry, Do Not Break Down Skid. 2 Item (Rule) 568, Heavy or Bulky Freight Loading or Unloading, employs the threshold limit of exceeding 8 feet (96 inches) in greatest dimension as the measurement at which freight becomes more difficult to load and unload when compared to general freight. Subject 1, Page 6 of 8

11 SUBJECT 1 Additionally, the manner in which flat glass is tendered for shipment may also have an impact on its susceptibility to damage. As noted, glass packaging generally does not provide lateral support for adjacent freight. Outriggers and other forms of bracing may be of sufficient strength to hold and stabilize glass sheets in an upright position during transit, but may not be able to support the additional load of co-loaded freight. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record reveals that movements of flat glass whether bent or not bent are shipped on edge (as required), in varying lengths and sizes. CCSB policy further provides that where commodities or commodity groups exhibit a wide range of densities not accurately reflected by a single class they may be assigned density-based classes. However, in this instance, research has identified several significant negative handling, stowability and liability issues that must also be considered, in accordance with CCSB policies. These factors have been detailed in the analysis and include such issues as the need for floor-loading, the inability to tier shipments and the inherent fragile nature of glass, among others, with yet additional handling and stowing difficulties presented by glass exceeding 96 inches in greatest dimension. Classification precedent has been to assign a higher class than that associated with the CCSB s density guidelines when there are unusual or significant handling, stowability or liability characteristics. In view of the information of record, it would be in keeping with CCSB policy and classification precedent to establish provisions based on greatest dimension and density, as proposed 3. As outlined in the discussion of density, the density figures are distributed throughout the range, but can be segregated into three clusters or groupings of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater. The table shown on the following page provides an evaluation of the density information of record on the basis of the three proposed density groups and shows the respective average density, the class based on CCSB density guidelines, and class adjustments to reflect the identified negative handling, stowing and liability considerations. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 1, Page 7 of 8

12 SUBJECT 1 Density Group (pcf) Average Density (pcf) Greatest Dimension Not Exceeding/ Exceeding 96 Class Based on CCSB Density Guidelines One-Class Adjustment for Greatest Dimension Not Exceeding 96 Two-Class Adjustment for Greatest Dimension Exceeding 96 Less than / but less than / or greater / Adding an attendant Note, as proposed, stating Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment, would be in keeping with CCSB policies with respect to clarification. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 1, Page 8 of 8

13 SUBJECT 2 Re: Household Washers (Washing Machines) Packaging CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: General Electric, Louisville, Kentucky Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Household: subject to item Washers (Washing Machines); or Parts thereof, NOI, other than metal, see Note, item ; in boxes, crates or Packages 122, 180, 1019, 1022, 1082, 1254, 2386 or Not Involved NOTE Not Involved. Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Household: subject to item Washers (Washing Machines); or Parts thereof, NOI, other than metal, see Note, item ; in boxes, crates or Packages 122, 180, 1019, 1022, 1082, 1254, 2386, 2408 or NEW... No Change NOTE No Change. Package NEW (1) ARTICLES: Household washers may be enclosed in a corrugated fiberboard shipping container with corner posts and protective pads. (2) EXTERIOR PACKAGING: (a) Article must be enclosed in a singlewall corrugated fiberboard full-height halfslotted container (HSC) having an ECT value of not less than 44 ECT. (b) A singlewall corrugated fiberboard top cap having an ECT value of not less than 44 ECT must be placed on top of article and extend not less than 4 inches from top of article. (c) Basiloid flap on body must have an 8-inch strip of not less than 42-pound Kraft paper. (d) Basiloid flap on top cap must have a 10-inch strip of not less than 69-pound Kraft paper. (e) Bottom flaps of container must be not less than 11 inches wide and must be securely closed with glue. Subject 2, Page 1 of 3

14 SUBJECT 2 Proposed Classification Provisions Concluded Package NEW (Continued) (f) One 1 /2-inch x inch metal band must be secured horizontally around top cap, securing to body. (3) INTERIOR PACKAGING: (a) Corners of article must be protected by 1.25 pcf expanded polystyrene corner posts. (b) Top and bottom of article must each be protected by 1.50 pcf expanded polystyrene form-fitting block pads. (c) Plastic film must be placed on top of non-white units. (4) MARKINGS: Do Not Lay Down This Side and pictorial markings indicating Stack 4 High and Do Not Forklift must be printed on all sides, see Note; Do Not Clamp From This Side must be printed on three sides; and other precautionary markings, as applicable, must be on at least two sides of the packaged article. (See Item 682.) Note If package is secured on lift truck skid or pallet forklift handling is permitted, and the 'Do Not Forklift' markings must be obliterated or securely covered. Analysis This proposal was submitted by General Electric (GE) to add a new numbered package for household clothes washers, as named in item The proponent s package was designed for front-load household clothes washers, such as that shown in the photo. The packaged washers measure 37 x 31 x 44 inches and 37 x 31 x 53 inches, and weigh 260 and 300 pounds, respectively. The difference in height and weight is the result of some units being shipped with a 7-inch riser attached, as outlined in the green box. The proponent estimates approximately 205 weekly shipments of these products via less-than-truckload (LTL) motor carrier (only 10% of their projected shipments). The full replacement value ranges from $1,099 to $1,399 per washer. Proposed Package Design The proponent s package is constructed of a singlewall corrugated fiberboard halfslotted container and singlewall corrugated fiberboard top cap with expanded polystyrene corner posts and top and bottom pads. Units that are not white must have plastic film placed on top of the unit. Prior to package testing, unpackaged washers were subjected to manual handling testing with a hand truck in and out of the box, up and down stairs, and sliding across rough surfaces, to simulate delivery into the home. This testing helped the proponent identify weakness in the product, prior to the package design phase. Subject 2, Page 2 of 3

15 SUBJECT 2 In order to test the integrity of the packaging, the proponent then subjected the packaged washers to a variety of ASTM International test procedures. The sequence simulated the dynamics of the proponent s distribution environment and included mechanical handling tests for clamp and Basiloid attachments, and vibration and drop (impact) testing. Each shipping container has a variety of instructions and precautionary markings to help facilitate the safe handling and stowing of the washers. As packaged, the washers may be stacked four high in warehousing, but only two high during shipment. These packages do not, however, allow for mechanical handling with forklifts; but they may be handled with clamp and Basiloid attachments, or they are to be handled manually. Based on discussions with the proponent, the majority (90%) of their freight is truckload and handled by their distribution centers, where the handling of the freight with clamp and Basiloid is universal. For those 10% of shipments that are tendered to LTL motor carriers, the distribution centers strap each packaged washer on a lift truck skid or pallet for ease of loading and unloading by the carrier and consignee. Relationship to CCSB Policies and Guidelines CCSB policies call on the CCSB to establish and maintain packaging specifications to ensure that freight is adequately protected in the motor carrier environment, and can be handled and stowed in a manner that is reasonably safe and practicable. Prospective packaging materials or methods are deemed to be consistent with CCSB packaging policies when they are demonstrated to be as good as, or better than, currently authorized materials or methods. The proponent s design would provide additional protection to household washers based on the successful testing through ASTM International test procedures. Therefore, it would be in keeping with CCSB policies and precedent to authorize the new package design for household washers, as proposed. Subject 2, Page 3 of 3

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17 SUBJECT 3 Re: Household Dryers (Drying Machines) Packaging CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: General Electric, Louisville, Kentucky Present Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Household: subject to item Dryers (Drying Machines), in boxes, crates or Packages 1019, 1022, 1082, 1254, 2386 or Not Involved Proposed Classification Provisions Item Description Class MACHINERY GROUP: subject to item Laundry: subject to item Household: subject to item Dryers (Drying Machines), in boxes, crates or Packages 1019, 1022, 1082, 1254, 2386, 2451 or NEW... No Change Package NEW (1) ARTICLES: Household dryers may be enclosed in a corrugated fiberboard shipping container with corner posts and protective pads. (2) EXTERIOR PACKAGING: (a) Article must be enclosed in a singlewall corrugated fiberboard container having an ECT value of not less than 44 ECT. (b) Basiloid flap on container must have an 8-inch strip of not less than 42-pound Kraft paper. (c) Bottom flaps of container must be not less than 6.5 inches wide and must be securely closed with glue. (d) Top flaps of container must cover the entire top of the unit and must be securely closed with glue and staples. (3) INTERIOR PACKAGING: (a) Corners of article must be protected by 1.25 pcf expanded polystyrene corner posts. (b) Two top and bottom edges of article must each be protected by 1.50 pcf expanded polystyrene form-fitting block pads. 1. Top pads to run side-to-side. 2. Bottom pads to run front-to-back. (c) Plastic film must be placed on top of non-white units. Subject 3, Page 1 of 3

18 SUBJECT 3 Proposed Classification Provisions Concluded Package NEW (Continued) (4) MARKINGS: Do Not Lay Down This Side and pictorial markings indicating Stack 5 High and Do Not Forklift must be printed on all sides, see Note; Do Not Clamp From This Side must be printed on three sides; and other precautionary markings, as applicable, must be on at least two sides of the packaged article. (See Item 682.) Note If package is secured on lift truck skid or pallet forklift handling is permitted, and the 'Do Not Forklift' markings must be obliterated or securely covered. Analysis This proposal was submitted by General Electric (GE) to add a new numbered package for household clothes dryers, as named in item dryer. The proponent s package was designed for front-load household clothes dryers, such as that shown in the photo. The packaged dryers measure 37 x 31 x 44 inches and 37 x 31 x 53 inches, and weigh 160 and 195 pounds, respectively. The difference in height and weight is the result of some units being shipped with a 7-inch riser attached, as outlined in the blue box. The proponent estimates approximately 185 weekly shipments of these products via less-than-truckload (LTL) motor carrier (only 10% of their projected shipments). The full replacement value ranges from $1,099 to $1,399 per Proposed Package Design The proponent s package is constructed of a singlewall corrugated fiberboard container with expanded polystyrene corner posts and edge protectors. Units that are not white must have plastic film placed on top of the unit. Prior to package testing, unpackaged dryers were subjected to manual handling testing with a hand truck in and out of the box, up and down stairs, and sliding across rough surfaces, to simulate delivery into the home. This testing helped the proponent identify weakness in the product, prior to the package design phase. In order to test the integrity of the packaging, the proponent then subjected the packaged dryers to a variety of ASTM International test procedures. The sequence simulated the dynamics of the proponent s distribution environment and included mechanical handling tests for clamp and Basiloid attachments, and vibration and drop (impact) testing. Each shipping container has a variety of instructions and precautionary markings to help facilitate the safe handling and stowing of the dryers. As packaged, the dryers may be stacked five high in warehousing, but only two high during shipment. These packages do not, however, allow for mechanical handling with forklifts; but they may be handled with clamp and Basiloid attachments, or they are to be handled manually. Based on discussions with the proponent, the majority (90%) of their freight is truckload and handled by their distribution Subject 3, Page 2 of 3

19 SUBJECT 3 centers, where the handling of the freight with clamp and Basiloid is universal. For those 10% of shipments that are tendered to LTL motor carriers, the distribution centers strap each packaged dryer on a lift truck skid or pallet for ease of loading and unloading by the carrier and consignee. Relationship to CCSB Policies and Guidelines CCSB policies call on the CCSB to establish and maintain packaging specifications to ensure that freight is adequately protected in the motor carrier environment, and can be handled and stowed in a manner that is reasonably safe and practicable. Prospective packaging materials or methods are deemed to be consistent with CCSB packaging policies when they are demonstrated to be as good as, or better than, currently authorized materials or methods. The proponent s design would provide additional protection to household dryers based on the successful testing through ASTM International test procedures. Therefore, it would be in keeping with CCSB policies and precedent to authorize the new package design for household dryers, as proposed. Subject 3, Page 3 of 3

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21 SUBJECT 4 Re: Cabinets or Lockers, storage or wardrobe, including Kitchen or Base Cabinets CCSB Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FURNITURE GROUP: subject to item Metallic or Wooden: subject to item Cabinets or Lockers, storage or wardrobe, NOI; Kitchen Cabinets, see Note, item 80473; Wall Cabinets, kitchen or bathroom, see Note, item 80474; Base Cabinets (Work Bases) or Sink or Stove Cabinets, see Notes, items 80475, and 80477: Metal other than steel, with or without glass: Sub 1 SU, in Packages 1F, 3F, 5F, 16F, 21F or 22F Sub 2 KD flat, in Packages 1F, 2F, 3F, 5F or 19F Steel, with glass: Sub 1 SU, in Packages 1F, 3F, 5F or 50F Sub 2 KD, in Packages 1F, 3F or 5F Steel, without glass, see Note, item 80462: Sub 1 SU, in crates or Packages 1F, 3F, 16F, 21F, 22F, 25F, 50F, 53F, 69F, 72F, 98F, 111F, 114F or 149F Sub 2 KD flat: Sub 3 In Package 9F Sub 4 In Packages 1F, 3F, 5F, 19F or in crates NOTE Also applies on steel cabinets with plastic drawers Wooden, see Note, item 80472: Sub 1 SU, in Packages 1F, 2F, 3F, 5F, 19F, 21F, 22F, 133F, 138F, 141F or 156F Sub 2 KD, in Packages 1F, 2F, 3F, 5F or 19F Sub 3 KD flat, in Packages 1F, 3F, 5F, 19F, 21F, 22F or 25F NOTE Also applies when made of fiberboard wallboard or fiberboard wallboard and wood or steel combined, or of wood particleboard NOTE Applies only on cabinets comprised of top and base sections, whether attached or separated NOTE Applies only on cabinets designed to be hung from or fastened to upper walls, other than bathroom medicine or toilet cabinets NOTE Applies only on free-standing cabinets or on cabinets to be attached to floors or lower walls, with or without sides or tops, and whether or not having tops or working surfaces of materials other than metal or wood NOTE Also applies on cabinets equipped with lavatories, sinks, refrigerators, stoves, or water heaters with or without pumping system, whether in same or separate packages. Lavatories, sinks, refrigerators, stoves or water heaters may be in packages authorized in individual items. Subject 4, Page 1 of 7

22 SUBJECT 4 Present Classification Provisions Concluded Item Description Class NOTE Wooden cabinets may also include faucets and drain fittings when shipped in same package with cabinet. Proposed Classification Provisions Item Description Class FURNITURE GROUP: subject to item Metallic or Wooden: subject to item Cabinets or Lockers, with or without components of other materials, see Notes, items A-NEW, B-NEW and C-NEW, viz.: Base Cabinets (Work Bases); Cabinets or Lockers, storage or wardrobe, NOI; Kitchen or Bathroom Cabinets, see Note, item D-NEW; Sink or Stove Cabinets; In crates or Packages 1F, 2F, 3F, 5F, 16F, 19F, 21F, 22F, 25F, 50F, 53F, 69F, 111F, 133F or 149F, see Note, item E-NEW, 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 or greater A-NEW NOTE Applies on free-standing cabinets or lockers or on cabinets or lockers to be attached to floors or walls. B-NEW NOTE Also applies on cabinets equipped with lavatories, sinks, refrigerators, stoves, or water heaters with or without pumping system, whether in same or separate packages. When in separate packages, lavatories, sinks, refrigerators, stoves or water heaters may be in packages authorized in individual items. C-NEW NOTE Cabinets may include faucets and drain fittings when shipped in same package with cabinet. D-NEW NOTE Does not apply on bathroom medicine or toilet cabinets. Subject 4, Page 2 of 7

23 SUBJECT 4 Proposed Classification Provisions Concluded Item Description Class FURNITURE GROUP: subject to item Metallic or Wooden: subject to item E-NEW NOTE The following departures from packing requirements are permitted: 1. Sink cabinets may be shipped in Packages 72F or 98F. 2. Wooden cabinets or lockers may be shipped in Packages 138F, 141F or 156F. 3. Steel cabinets or lockers may be shipped in Package 114F Metal other than steel, with or without glass, etc... Cancel; see item Steel, with glass, etc... Cancel; see item Steel, without glass, etc... Cancel; see item NOTE Cancel; no further application Wooden, etc... Cancel; see item NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; see item D-NEW NOTE Cancel; see item A-NEW NOTE Cancel; see item B-NEW NOTE Cancel; see item C-NEW. Analysis Research Project 1159 This proposal is based on information developed through Research Project 1159, which was initiated in March of 2012 in response to numerous interpretative issues involving cabinets or lockers provided for in items 80440, 80445, 80450, and As part of the research, the CCSB mailed commodity questionnaires to 198 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 July of 2012, and again in November of 2012 to those that did not respond to the initial mailing. From this sampling, seven of the shipper questionnaires were returned as undeliverable, six companies responded that they did not manufacture or ship the involved articles, and seven companies provided at least some information; however, not all of the information was usable, with most respondents indicating that there were too many variations to list. With respect to the associations, three indicated that their members did not manufacture or ship the involved articles, and one provided some general information on behalf of their members. Subject 4, Page 3 of 7

24 SUBJECT 4 History of Provisions Provisions for cabinets or lockers as currently named in item were adopted from the rails in Since that time, there have been amendments to these provisions, including class adjustments, packaging changes, the addition of other materials of construction and the addition of explanatory or clarifying Notes. About Cabinets or Lockers Cabinets or lockers are ubiquitous box-type products used for storing materials, supplies and other articles. They may be free-standing or designed to be anchored on the floor or mounted on a wall. They are made from a variety of different materials, including metal, wood and combinations of materials depending upon their intended use or desired aesthetic quality, and may or may not be equipped with tops of the same or other materials. Cabinets can also be equipped with articles such as sinks. Examples of different types of cabinets or lockers are shown below: Subject 4, Page 4 of 7

25 SUBJECT 4 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 45,683 density observations resulting in a density range from 0.08 to pcf, with a simple average density of 7.68 pcf. A frequency distribution of the overall density range is shown below: Frequency Distribution % of Figures in Interval 35.00% 30.00% 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 31.58% 21.25% 17.20% 8.76% 6.96% 4.95% 5.11% 0.05% 1.96% 1.20% 0.98% Density Intervals (pcf) Handling and Stowability Cabinets or lockers are generally tendered in fiberboard containers on lift truck skids or pallets. They may also be tendered in wooden crates or complying F Packages. While there is no indication that cabinets or lockers are more difficult to handle and stow than other like-packaged freight, the packages are frequently marked with directional arrows, which may restrict how the carrier can construct the load within the vehicle. Also, some of these articles may have glass components and, therefore, may require a certain degree of care in handling and stowing. However, there have been no reports of unusual or significant handling or stowability problems. Liability Cabinets or lockers, as with other types of furniture, are inherently susceptible to damage, particularly when not packaged in accordance with the minimum packaging requirements specified in the NMFC TM. Only one carrier reported claims ratios, which ranged from 0.36% to 3.21%; however, this limited information does not necessarily indicate an unusual 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. Subject 4, Page 5 of 7

26 SUBJECT 4 claims issue. Information regarding value per pound, while extremely limited, indicates a range from $53.04 to $55.36 per pound, with a simple average value of $54.20 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to be as clear as possible to help preclude interpretation disputes. The current provisions, which assign classes based on material construction and form of shipment, have been the source of interpretation difficulties. CCSB policy also calls for classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that the involved cabinets or lockers range in density from 0.08 to pcf, with a simple average density of 7.68 pcf. CCSB policy 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; especially where there are no unusual or significant handling, stowability or liability characteristics and where there is no other feasible means of effectively narrowing the range. And where densities are distributed throughout the range, commodities or commodity groups may be assigned classes predicated on a full density scale. Further, unless a substantial percentage of the densities involved exceeds 20 pcf, full-scale density classifications should generally provide the standard nine-sub progression that ranges from class 400 assigned to articles with densities of less than 1 pcf to class 70 assigned to articles with densities of 15 pcf or greater. In this instance, only 3.08% of the density observations exceed 20 pcf and, consequently, this proposal would establish classes predicated on the CCSB s standard ninesubprovision full density scale 2. Such an approach would be in keeping with CCSB precedent. An example may be found in CCSB Docket , Subject 1 (June 2010), which was a proposal to establish the CCSB s nine-subprovision density scale for Clothing, as named in item Information from the record indicated densities ranging from 0.64 to pcf, with a simple average density of 7.68 pcf, and less than 2% of the figures exceeded 20 pcf. The proposal was approved as docketed, and the changes first appeared in Supplement 4 to NMF 100-AJ, effective December 25, In keeping with CCSB policy, this proposal would cancel the provisions of items 80445, 80450, and with reference to item Concurrently, the description of item would be amended to provide a viz. format in the interest of clarification and simplification. Classes would be based on the CCSB s standard nine-subprovision density progression, as previously mentioned. With the cancellation of items 80445, 80450, and 80470, this proposal would also cancel Notes, items 80462, and as having no further application. Notes, items 80474, 80475, and would be canceled with reference to new Notes to item 80440, in keeping with CCSB clarification policy. 2 The CCSB s standard nine-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. Subject 4, Page 6 of 7

27 SUBJECT 4 CCSB packaging policy calls for the CCSB to establish and maintain packaging specifications as necessary to ensure that freight is adequately protected in the motor carrier environment, and can be handled and stowed in a manner that is reasonably safe and practicable. Based on a review of the presently authorized packages by the CCSB s Packaging Consultant, who has determined that the majority of the currently authorized F Packages are suitable for cabinets or lockers regardless of whether they are made of wood or metal, this proposal would make these packages applicable to all of the involved articles. The few packages identified as being applicable to a specific type of cabinet or locker would be addressed in a proposed new Note, and reference to Package 9F would be removed. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 4, Page 7 of 7

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29 SUBJECT 5 Re: Item (Rule) 110, Sec. 8, Determination of Density CCSB Contact: William F. Mascaro Telephone (703) mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions ITEM 110* DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES The following definitions will apply when such terms are used in this Classification or in tariffs governed by this Classification. When different definitions are provided for the same terms in connection with rates, classes, rules or other provisions, such definitions will take precedence. Secs (c) Not Involved. Sec. 8. Density. Except as otherwise provided, where classes are based on the density of articles as tendered for shipment, the word density refers to the actual density of each handling unit so tendered, as measured in pounds per cubic foot. (See Sec. 8 (c).) Sec. 8. (a) To determine the density of each handling unit, first determine the cubage of the handling unit by multiplying the greatest straight-line dimensions of length, width and height (depth) in inches, including all projections, if any, as tendered to the carrier for shipment, and dividing the total by 1,728 cubic inches (one cubic foot). The density is the result of the division of the weight of the handling unit as tendered for shipment by the cubic feet. For instance, the density of a handling unit consisting of boxes unitized on a lift truck pallet measuring 48" x 40" x 45" and weighing 450 pounds is determined as follows: 48" x 40" x 45" = 86,400 cubic inches; 86,400 1,728 = 50 cubic feet; 450 lbs. 50 = 9.00 pounds per cubic foot (pcf). Sec. 8. (b) To determine the density of a cylindrical-shaped handling unit, square the greatest dimension on the cylindrical plane by multiplying the dimension by itself in inches and then multiplying that result by the height or length. Divide the result by 1,728 cubic inches. The density is the result of the division of the weight of the handling unit by the cubic feet. Sec. 8. (c) Where articles are unitized on lift truck pallets, platforms, racks or skids, the pallet, platform, rack or skid constitutes an integral part of the handling unit, and except as provided in Item 640, Sec. 3 (b), must be included in the computation of density. Secs Not Involved. *Published in Supplement 1 to NMF 100-AM, issued on March 21, 2013 with an effective date of April 20, Subject 5, Page 1 of 3

30 SUBJECT 5 Proposed Classification Provisions ITEM 110 DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES The following definitions will apply when such terms are used in this Classification or in tariffs governed by this Classification. When different definitions are provided for the same terms in connection with rates, classes, rules or other provisions, such definitions will take precedence. Secs (c) No Change. Sec. 8. Density. Where classes are based on the density of articles as tendered for shipment, the word density refers to the actual density of the articles shipped, as measured in pounds per cubic foot. Sec. 8. (a) To determine the density of a handling unit, first determine the cubage of the handling unit by multiplying the greatest straight-line dimensions of length, width and height (depth) in inches, including all projections, if any, as tendered to the carrier for shipment, and dividing the total by 1,728 cubic inches (one cubic foot). The density is the result of the division of the weight of the handling unit as tendered for shipment by the cubic feet. For instance, the density of a handling unit consisting of boxes unitized on a lift truck pallet measuring 48" x 40" x 45" and weighing 450 pounds is determined as follows: 48" x 40" x 45" = 86,400 cubic inches; 86,400 1,728 = 50 cubic feet; 450 lbs. 50 = 9.00 pounds per cubic foot (pcf). Sec. 8. (b) To determine the density of a cylindrical-shaped handling unit, square the greatest dimension on the cylindrical plane by multiplying the dimension by itself in inches and then multiplying that result by the height or length. Divide the result by 1,728 cubic inches. The density is the result of the division of the weight of the handling unit by the cubic feet. Sec. 8. (c) Where articles are unitized on lift truck pallets, platforms, racks or skids, the pallet, platform, rack or skid constitutes an integral part of the handling unit, and except as provided in Item 640, Sec. 3 (b), must be included in the computation of density. Sec. 8. (d) Unless otherwise provided, where a shipment consists of multiple handling units the density shall be calculated on each handling unit, except that where shipping papers show only a total weight for all handling units tendered the density may be calculated by using the total weight and the total cube. Secs No Change. Analysis and Relationship to CCSB Policies and Guidelines Subject 13 of Docket (January 2013) was a proposal that sought to clarify the application of Item (Rule) 110, Sec. 8, governing the determination of density, in response to interpretative inquiries from carriers, shippers and logistics companies. These inquiries have generally centered on the question of whether density must be calculated on each handling unit or instead on the total cube and total weight of the shipment. The CCSB has consistently responded to such inquiries that, unless otherwise provided, density should be determined for each handling unit based on its dimensions and weight as tendered for shipment to the carrier. The proposal reflected this interpretation. Subject 5, Page 2 of 3

31 SUBJECT 5 At the CCSB s public meeting on January 29, 2013 where Docket was considered, numerous interested parties expressed both support for, and opposition to, the proposal. Parties that supported the proposal took the position that the proposed amendments were strictly clarifying in nature and accurately reflected the proper manner of determining density. However, interested parties who spoke against the proposal expressed their belief that the proposed changes went beyond clarification and would, if approved, unnecessarily render certain density computation methodologies noncompliant; in particular, where shipments consist of multiple handling units. After considerable discussion, the CCSB approved the proposal as docketed, and the changes went into effect on April 20, 2013 in Supplement 1 to NMF 100-AM. However, in response to the discussion, the CCSB initiated a further review of Item 110, Sec. 8, and the manner in which density is determined for shipments consisting of multiple handling units. The CCSB's review found no single method being universally used. But it was found that, where shipments consist of multiple handling units and the shipping papers show only a total weight for all of the handling units tendered, density is frequently calculated using the total weight and the total cube. CCSB policy stipulates that rules published in the NMFC TM are to be consistent with current motor carrier practice and clear as to intent. This proposal would amend Item 110 for clarification and to reflect current motor carrier practice with respect to the determination of density. Based on the information of record, this proposal is in keeping with CCSB policy. Subject 5, Page 3 of 3

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33 SUBJECT 6 Re: Earphones, Headphones or Headsets CCSB Contact: Nathan D. Ripke Telephone (703) ripke@nmfta.org Shannon C. Allard (703) allard@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item Electrical Appliances or Instruments, NOI, see Note, item 61701, in boxes, crates or Packages 829, 1241 or 2112, 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 Radio, Radio-telephone or Television Transmitting or Transmitting and Receiving Sets, or other Radio Impulse or Wireless Audio (Sound) Impulse Transmitting or Transmitting and Receiving Sets, separate or combined, in boxes, crates or Package 231, see Note, item 62822: Sub 1 Released value not exceeding $3.00 per pound Sub 2 Released value exceeding $3.00 per pound but not exceeding $6.00 per pound Sub 3 Released value exceeding $6.00 per pound but not exceeding $10.00 per pound NOTE Not Involved. Subject 6, Page 1 of 5

34 SUBJECT 6 Proposed Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item NEW Earphones, Headphones or Headsets, in boxes Electrical Appliances or Instruments, NOI, see Note, item 61701, etc.... No Change NOTE No Change Radio, Radio-telephone or Television Transmitting or Transmitting and Receiving Sets, or other Radio Impulse or Wireless Audio (Sound) Impulse Transmitting or Transmitting and Receiving Sets, etc.... No Change NOTE No Change. Analysis Research Project 1167 This proposal is based on information developed through Research Project 1167, which was initiated in August 2012 in response to numerous interpretation questions regarding the applicable provisions for products described as earphones, headphones or headsets. While earphones, headphones or headsets are not specifically named in the NMFC, CCSB opinions have generally classified these commodities under the provisions of items or 62820, as shown in the present provisions. During the course of the project, questionnaires were mailed to 189 potential manufacturers or shippers and 26 trade associations in November of 2012, and again to those that did not respond, in January of 2013, inviting them to participate in the research. From this sampling, 10 questionnaires were returned as undeliverable, three companies responded that they did not ship the involved articles, and 10 companies provided some information; however, not all of the information was usable. Regarding the 26 trade associations contacted, 14 responded that they did not represent manufacturers or shippers of the involved articles. No response was received from the remaining associations. Subject 6, Page 2 of 5

35 SUBJECT 6 About Earphones, Headphones or Headsets The information of record encompasses a variety of earphones, headphones or headsets, including wired and wireless. As shown in the examples below, there are many sizes and configurations depending on the function of the product. Typical functions include listening to audio, transmitting or receiving communication signals, and/or noise reduction or cancellation. Transportation Characteristics Density Information of record includes 369 density observations submitted by shippers and carriers, obtained during CCSB dock surveys and culled from the CCSB Density Study 1. The products range in density from 1.90 to pcf, with a simple average density of 5.64 pcf. A frequency distribution for earphones, headphones or headsets is presented on the following page. 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. Subject 6, Page 3 of 5

36 SUBJECT 6 % of Figures in Interval 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% Frequency Distribution 59.62% 13.55% 15.45% 8.40%1.63% 0.00% 0.54% 0.54%0.00%0.00%0.27% Density Intervals (pcf) As the above frequency distribution depicts, the greatest concentration of figures over 88% are clustered between 2 and 8 pcf, with over 59% of the figures within the 4 but less than 6 pcf interval. Handling and Stowability The information of record indicates that the involved articles are generally tendered for shipment in fiberboard boxes of regular size and shape, which are securely fastened to lift truck skids or pallets. While some shippers advise the carriers to Do Not Stack shipments, there have been no reports of unusual or significant handling or stowability problems. Liability While liability has long been a concern of carriers with respect to various electronic goods, earphones, headphones or headsets are not shown to be unusually susceptible to theft, liable to damage or likely to damage other freight. With regards to claims, two carriers reported a claims ratio of zero, while another carrier reported their claims ratios to be 0.06% and 0.03% for items and 62820, respectively. The overall value per pound ranges from $0.25 to $57.50, with a simple average value of $23.70 per pound. Subject 6, Page 4 of 5

37 SUBJECT 6 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. Earphones, headphones or headsets are not specifically named within the Classification, which has resulted in confusion as to the applicable provisions for these commodities. This proposal would establish a new, specific item for earphones, headphones or headsets. Additionally, CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record for earphones, headphones or headsets shows a range in density from 1.90 to pcf, with a simple average density of 5.64 pcf. As shown in the frequency distribution on page 4, the preponderance of density figures are concentrated within a narrow range around the overall average. Under CCSB guidelines, an average density of 5.64 pcf is generally associated with a class 175, which calls for a minimum average density of 5 pcf. This proposal would assign class 175. A similar approach was taken on Docket , Subject 2 (October 2009), involving item 28160, for footwear. No significant handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. As with earphones, headphones or headsets, footwear exhibited a wide range of densities from 1.00 to pcf with a significant concentration of density observations nearly 78% clustered around the overall average density of 6.28 pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal was approved as docketed, assigning class 150, and the provisions first appeared in Supplement 5 to NMF 100- AI, effective January 9, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 6, Page 5 of 5

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39 SUBJECT 7 Re: Cabinets, fire hose or fire extinguisher storage Item CCSB Contact: Nathan D. Ripke Telephone (703) ripke@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class CABINETS, OR PARTS NAMED: subject to item Fire Hose or Fire Extinguisher Storage, separate or combined, with or without glass, in boxes or crates Proposed Classification Provisions Item Description Class CABINETS, OR PARTS NAMED: subject to item Fire Hose or Fire Extinguisher Storage, separate or combined, with or without glass, in boxes or crates Analysis Research Project 1173 This proposal is based on information developed through Research Project 1173, which was initiated in December of 2012 to review the transportation characteristics of fire hose or fire extinguisher storage cabinets. During the course of the research project, 207 potential shippers or manufacturers and 10 associations believed to represent those companies were contacted in February, and for those that did not respond, again in April of 2013, inviting them to participate in the research. From those mailings, 23 companies indicated that they do not ship or manufacture the involved products. Three companies supplied information; however, not all of the information was usable. One association replied in a letter to confirm their receipt of the questionnaire and indicated that it would be forwarded to their membership. History of Provisions The provisions for fire hose storage cabinets first appeared in Supplement 10 to NMFC No. 5, effective December 20, 1941, at the equivalent of class 100. As a result of action taken on Special Docket No. 1 (issued July 20, 1949), the current class 110 was assigned to remain competitive with the rails. That change first appeared in NMFC A-1, effective July 10, The provisions were amended as a result of action taken on Docket 98, Subject 50 (March 1961), to include fire extinguisher storage cabinets, with no class change. Information on that record indicated that fire hose and fire extinguisher storage cabinets exhibited very similar or comparable transportation characteristics. Both commodities were believed to have an Subject 7, Page 1 of 4

40 SUBJECT 7 average density around 9 pcf, and an average value per pound around $1.70 (in 1961 dollars). There were no significant handling, stowability or liability concerns reported on that record. Those changes first appeared in Supplement 14 to NMFC A-5, effective October 25, 1961, and the provisions have remained substantially unchanged to the present. About Fire Hose or Fire Extinguisher Storage Cabinets Fire hose or fire extinguisher storage cabinets are composed of metal, wood and/or plastic, and may or may not have a see-through glass or plastic door. They are used in a variety of settings where it is necessary to cover and store a fire hose or fire extinguisher. The cabinets can vary in size depending on the length of the hose and/or the size of the fire extinguisher to be stored within the cabinet. Examples of the involved products are shown below. It should be noted that this proposal only addresses the cabinets themselves and not the fire hose or fire extinguisher. Provisions for those commodities are found elsewhere in the Classification. Subject 7, Page 2 of 4

41 SUBJECT 7 Transportation Characteristics Density The information of record includes 1,529 density observations obtained from carriersubmitted Shipment Information Forms and the CCSB s Density Study 1. The products range in density from 1.18 to pcf, with an average density of 6.75 pcf. The frequency distribution below shows that over 94% of the figures fall between 2 and 12 pcf. Frequency Distribution % of Figures in Interval 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% 0.00% 0.07% 11.84% 43.03% 21.06% 9.29%9.16% 2.81%1.77%0.72%0.26% Density Intervals (pcf) Handling and Stowability Fire hose or fire extinguisher storage cabinets are shipped in boxes or crates; boxes may or may not be unitized for shipment on lift truck skids or pallets. Handling and stowability should be comparable to that of other like-packaged freight. Some of these cabinets have glass components and, therefore, should be handled and stowed with a certain degree of care. However, there have been no reports of any unusual or significant handling or stowability problems. Liability The involved products are not perishable, nor are they prone to spontaneous combustion or explosion. These cabinets are not likely to damage other freight, and there is no indication that they are unusually susceptible to theft or liable to damage. One carrier reported a claims ratio of 1.34 % for these commodities, just above the 1% threshold considered typical for LTL freight operations. No value information has been obtained. 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. Subject 7, Page 3 of 4

42 SUBJECT 7 Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record indicates that fire hose or fire extinguisher storage cabinets range in density from 1.18 to pcf, with an average density of 6.75 pcf, and no unusual or significant handling, stowability or liability characteristics. As shown in the frequency distribution on page 3, the preponderance of density figures are concentrated within a narrow range around the overall average. An average density of 6.75 pcf is generally associated with a class 150 under CCSB density guidelines, which call for a minimum average density of 6 pcf. This proposal would assign item class 150 in lieu of the current class 110. A similar approach was taken on Docket , Subject 2 (October 2009), involving item 28160, for footwear. No significant handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. As with fire hose or fire extinguisher storage cabinets, footwear exhibited a wide range of densities from 1.00 to pcf with a significant concentration of density observations nearly 78% clustered around the overall average density of 6.28 pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal was approved as docketed, assigning class 150, and the provisions first appeared in Supplement 5 to NMF 100-AI, effective January 9, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 7, Page 4 of 4

43 SUBJECT 8 Re: Cookers, Grills or Smokers, outdoor, ceramic CCSB Contact: George M. Beck Telephone (703) beck@nmfta.org Allison L. Austin (703) austin@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class CHINA GROUP: subject to item Chinaware, Earthenware, Porcelainware or Stoneware, NOI, released to value not exceeding $90.00 per 100 pounds, see Note, item 47514, in boxes, crates, drums or Package Chinaware, Earthenware, Porcelainware or Stoneware, NOI, not released to value of $90.00 per 100 pounds, in boxes, crates, drums or Package NOTE Not Involved. Proposed Classification Provisions Item Description Class BOILERS, FURNACES, STOVES AND RELATED ARTICLES GROUP: subject to item A-NEW Broilers, Grills, Roasters or Smokers, cooking, portable, outdoor type, charcoal burning, kamado style, ceramic, with or without components of other materials, see Note, item B-NEW, in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 10 or greater B-NEW NOTE Also applies on complementary carts, tables, side shelves or other accessories in same package. CHINA GROUP: subject to item Chinaware, Earthenware, Porcelainware or Stoneware, NOI, released to value not exceeding $90.00 per 100 pounds, etc.... No Change Chinaware, Earthenware, Porcelainware or Stoneware, NOI, not released to value of $90.00 per 100 pounds, etc.... No Change NOTE No Change. Analysis Research Project 1151 This proposal is based on information developed through Research Project 1151, pertaining to outdoor ceramic cookers, grills or smokers. Hereinafter these products will be referred to as ceramic grills. Subject 8, Page 1 of 4

44 SUBJECT 8 Research Project 1151 was initiated in February 2012 in response to several interpretation inquiries regarding the applicable provisions for ceramic grills. Provisions in the NMFC for similar outdoor cooking units are restricted by material consist. As such, CCSB opinions have held the general provisions of items or 47510, for Chinaware, Earthenware, Porcelainware or Stoneware, NOI, applicable. As part of the research, 14 potential manufacturers or shippers and one trade association believed to represent those companies were sent commodity questionnaires in March, and for those that did not respond, again in May of Two questionnaires were returned as undeliverable and two companies responded affirmatively; however, only one company provided usable information. The one association contacted, the Hearth, Patio and Barbecue Association (HPBA), responded and agreed to forward the questionnaire to its membership. About Ceramic Grills In the outdoor cooking industry, ceramic grills are often described as kamado style 1. Based on ancient earthenware cooking technology, modern kamado-style ceramic grills typically include a dome top, bottom draft door and firebox. While the product may be constructed of various materials, the shell, firebox and/or fire ring are made of ceramic. As shown in examples below, ceramic grills may be placed in carts or tables for ease of use and/or portability. Transportation Characteristics Density The information of record for ceramic grills includes 25 density observations submitted by shippers and carriers, and obtained during CCSB dock surveys. The products range in density from 4.26 to pcf, with a simple average density of pcf. A frequency distribution is shown on the following page. 1 (accessed June 24, 2013) Subject 8, Page 2 of 4

45 SUBJECT 8 Frequency Distribution % of Figures in Interval 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 24.00% 20.00% 20.00% 16.00% 12.00% 8.00% 0.00% 0.00% 0.00% 0.00% 0.00% Density Intervals (pcf) As shown in the above frequency distribution, the densities are distributed throughout the range. However, the data can be divided into two density groups of less than 10 pcf, and 10 pcf or greater. These two groupings reflect a fairly even split of the distribution, with 52% of the figures less than 10 pcf and 48% of the figures 10 pcf or greater. When the data is evaluated on this basis, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling and Stowability Ceramic grills are typically tendered for shipment in fiberboard boxes on lift truck skids or pallets. In some instances, packages are labeled with precautionary markings or handling instructions, such as Fragile, This Side Up, and Do Not Double Stack. However, no significant handling or stowability problems have been reported. Liability Ceramic grills are not perishable, prone to spontaneous combustion or explosion, unusually susceptible to theft, unusually liable to damage or likely to damage other freight. One carrier reported a claims ratio of 0.21% for these commodities, well below the 1% threshold considered typical for LTL freight operations. The value per pound, based on the limited value data available, ranges from $3.37 to $3.48, for an average of $3.42. Subject 8, Page 3 of 4

46 SUBJECT 8 Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classifications for commodities that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. Over the years, the CCSB has received several interpretation inquiries regarding the applicable provisions for ceramic grills. Opinions have held the general provisions of items or 47510, for Chinaware, Earthenware, Porcelainware or Stoneware, NOI, applicable. This proposal would address the interpretation issues by establishing specific provisions for ceramic grills. CCSB policy also calls for provisions to reflect a commodity s known transportation characteristics. Information of record for ceramic grills shows a range in density from 4.26 to pcf, with an average density of pcf. Under CCSB density guidelines, an average density of pcf is generally associated with a class 100, which calls for a minimum average density of 9 pcf. However, CCSB policies further 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. As shown in the table below, the data can be divided into two density groupings of less than 10 pcf, and 10 pcf or greater, with classes reflective of the average density of each respective grouping. Density Group (pcf) Average Density (pcf) Guideline Class Density Guideline (pcf) Less than or greater Establishing a new item naming Broilers, Grills, Roasters or Smokers, cooking, portable, outdoor type, charcoal burning, kamado style, ceramic, with or without components of other materials, with a single density break at 10 pcf 2, would be in keeping with CCSB policy and precedent. A new Note would be established to state that the provisions also apply on complementary accessories in the same package. A similar approach was taken on Docket , Subject 11 (June 2009), involving engine radiator, fuel tank or oil filler caps, as named in item No significant negative handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. While the densities were distributed throughout the range of 2.96 to pcf, a single density break at 15 pcf was proposed to provide a more accurate reflection of the identified range in density. That proposal was approved as docketed, and the provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 2 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 8, Page 4 of 4

47 SUBJECT 9 Re: Skateboards CCSB Contact: Shannon C. Allard Telephone (703) allard@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ATHLETIC GOODS GROUP: subject to item Skateboards, with wheels attached, without posts or standards, see Note, item 17301, in boxes NOTE Does not apply on motorized skateboards. For provisions applicable to motorized skateboards, see items and Proposed Classification Provisions Item Description Class ATHLETIC GOODS GROUP: subject to item Skateboards, with wheels attached, without posts or standards, see Note, item 17301, in boxes, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 7 or greater NOTE Does not apply on motorized skateboards. For provisions applicable to motorized skateboards, see items and Analysis Research Project 1172 Research Project 1172 was initiated in December 2012 to investigate the transportation characteristics of skateboards, as named in item During the course of the project, questionnaires were mailed to 261 potential manufacturers or shippers and 15 trade associations in December of 2012, and again to those that did not respond, in February of 2013, inviting them to participate in the research. From this sampling, 10 questionnaires were returned as undeliverable, nine companies responded that they did not manufacture or ship the involved articles, and nine companies provided some information; however, not all of the information was usable. Regarding the 15 trade associations contacted, two responded that they did not represent manufacturers or shippers of the involved articles. No response was received from the remaining associations. Subject 9, Page 1 of 4

48 SUBJECT 9 Additional information was obtained through CCSB dock surveys, carrier-submitted Shipment Information Forms and the CCSB Density Study 1. History of Provisions Item for skateboards was established as a result of action taken on Docket 117, Subject 14 (January 1965). The provisions were approved as modified at the current class 70 and first appeared in Supplement 4 to NMFC A-8, effective July 13, Action taken on Docket , Subject 12 (November 2003) established Note, item 17301, to clarify that the provisions of item exclude motorized skateboards. Note, item 17301, first appeared in Supplement 1 to NMF 100-AD, effective January 24, The provisions of item and Note, item have remained unchanged to the present 2. About Skateboards Item is limited to skateboards, with wheels attached, without posts or standards. A skateboard is a board with wheels fixed to the bottom of each end, on which a person can ride in a standing or crouching position. Skateboards can vary in material construction (e.g. fiberglass, plastic or wood) and configuration. Their size and shape is often dependent upon the function of the skateboard itself. Examples of skateboards are shown in the photos below. 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. 2 Following the approval of Docket , Subject 12, Research Project 949 was initiated to review the transportation characteristics of skateboards moving under item No information was obtained, and as a result, Research Project 949 was canceled. Subject 9, Page 2 of 4

49 SUBJECT 9 Transportation Characteristics Density Information of record includes 877 density figures ranging from 2.44 to pcf, with a simple average density of 8.13 pcf. A frequency distribution for skateboards is presented below. Frequency Distribution % of Figures in Interval 30% 25% 20% 15% 10% 5% 0% 0.00% 0.00% 1.48% 27.48% 29.76% 27.37% 5.13% 2.85% 5.02% 0.68% 0.23% Density Intervals (pcf) When the data for skateboards is evaluated on the basis of the proposed density break at 7 pcf, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than or greater Handling and Stowability The information of record indicates that skateboards are generally tendered for shipment in fiberboard boxes of regular size and shape on lift truck skids or pallets. Skateboards do not present significant handling or stowability concerns. Liability Skateboards are not perishable, prone to spontaneous combustion or explosion, unusually susceptible to theft, unusually liable to damage, and would not appear likely to damage other freight. Responding shippers indicate minimal to no claims on this commodity, and carriers report zero claims for skateboards. Value per pound ranges from $7.33 to $25.75, with a simple average value of $20.85 per pound. Subject 9, Page 3 of 4

50 SUBJECT 9 Relationship to CCSB Policies and Guidelines CCSB policies state that existing classifications should be amended to reflect a commodity s known transportation characteristics. Information of record shows densities for the involved skateboards range from 2.44 to pcf, with a simple average density of 8.13 pcf. This is inconsistent with the current class 70, which calls for a minimum average density of 15 pcf, per CCSB guidelines. CCSB policy further provides that commodities or commodity groups exhibiting a wide range in density not accurately reflected by a single overall average density may be assigned density-based classes; especially where there are no unusual or significant handling, stowability or liability concerns. As shown in the table below, the density data has been evaluated based on the proposed density break at 7 pcf, with classes reflective of the average density of each grouping 3. Density Group (pcf) Average Density (pcf) Guideline Class Density Guideline (pcf) Less than or greater This proposal is consistent with classification precedent. A similar approach was taken on Docket , Subject 11 (June 2009), involving engine radiator, fuel tank or oil filler caps, as named in item Density was determined to be the primary transportation characteristic since there were no significant negative handling, stowability or liability concerns reported. While the densities were distributed throughout the range of 2.96 to pcf, a single density break at 15 pcf was proposed to provide a more accurate representation of the identified range in density. That proposal was approved as docketed, and the provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. Subject 9, Page 4 of 4

51 SUBJECT 10 Re: Item (Rule) 181, Furniture Package Performance Testing CCSB Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 181, Furniture Package Performance Testing, to read as follows: ITEM 181 FURNITURE PACKAGE PERFORMANCE TESTING [Introductory Paragraphs No Change.] Orientation and Nomenclature for Test Specimens 1 : Place the container in its normal shipping orientation with the front facing forward and then proceed with marking the faces according to the diagram shown below. Note the Manufacturer s Joint, when present, may or may not be located in the same position as shown in the diagram. PERFORMANCE TEST REQUIREMENTS: All applicable shipping units must be tested as follows: No Change. Section I. Conditioning 1 This procedure does not apply on shipping containers secured on a lift truck skid or pallet, or with a lift truck skid or pallet base. Subject 10, Page 1 of 8

52 SUBJECT 10 Proposed Classification Provisions Continued Section II. Compression/Vibration Test Two alternate methods of testing are permissible: Method (A) Stacked Compressive Load/Vibration Testing, or Method (B) Separate Compressive Load/Vibration Testing. Either may be utilized, depending on test capability or product characteristics. Unless the shipping container is marked with upright arrow symbols, the container must be tested on Faces 3, 4 and 6. If the shipping unit is marked with upright arrow symbols, the compressive load or force requirements in Methods (A) and (B) for Faces 4 and 6 may be omitted. Method (A) Stacked Compressive Load/Vibration Testing Shipping units must be vibration tested under a stacked compressive load using either an identical shipping unit, or a concentrated dead weight load as described below. (1) Calculating Concentrated Dead Weight Loads: When conducting concentrated dead weight load vibration tests, the size of the package changes with the three shipping orientations of the package, and the concentrated dead load weights on the top of the package will change accordingly. Use a concentrated dead load (see Description of Load Apparatus in Paragraph (2)(a) below) to simulate miscellaneous freight loaded on top of a floor-stowed shipping unit in a trailer. Determine the required loads, rounded up to the nearest 5 pounds (lbs), from the formulas in Table 1 or 2. See Notes 2 and 3. Table 1: Method (A) Load Calculation Orientation Face 3 Down: LOAD = 10 x (108 h) x (l x w) 1728 Orientation Face 4 Down: LOAD = 10 x (108 w) x (l x h) 1728 Orientation Face 6 Down: LOAD = 10 x (108 l) x (w x h) 1728 Where: LOAD = pounds (lbs) average density of LTL freight 10 = (pcf) 108 = inside height of trailer (in) 1728 = conversion factor (in 3 /ft 3 ) h = height of shipping unit (in) l = length of shipping unit (in) w = width of shipping unit (in) Subject 10, Page 2 of 8

53 SUBJECT 10 Proposed Classification Provisions Continued Table 2 2 : Method (A) Load Calculation (Metric) Orientation Face 3 Down: LOAD = 162 x (2.7 h) x (l x w) x 9.8 Orientation Face 4 Down: LOAD = 162 x (2.7 w) x (l x h) x 9.8 Orientation Face 6 Down: LOAD = 162 x (2.7 l) x (w x h) x 9.8 Where: LOAD = kilograms (kg) average density of LTL freight 162 = (kg/m 3 ) 2.7 = inside height of trailer (m) h = height of shipping unit (m) l = length of shipping unit (m) w = width of shipping unit (m) 9.8 = metric conversion factor (m/s 2 ) NOTE 2 If the package weighs less than 30 lbs (14 kg) or is 2 ft 3 (0.056 m 3 ) or less in size, the factor is reduced to 54 in (1.4 m) instead of 108 in (2.7 m). 3 NOTE 2 To avoid any gross distortion of calculated loads, a maximum dead load of 750 lbs (340 kg) should be utilized when the calculated dead load exceeds this limitation. NOTE 3 For step or form-fitting containers, the load may be applied proportionately, dividing the total load by the surface area of the panels formed by stepping. (2)(a) Description of Load Apparatus: The concentrated dead load shall consist of the following: corrugated trays or HSC-style container(s) of doublewall construction having a corrugated medium maximum basis weight of 33 lbs (15 kg); a plywood sheet with a minimum thickness of 0.5 in (13 mm) resting inside the container on the complete area of the bottom inner flaps of the container; and a block of lead or sand contained in plastic bag(s) evenly distributed over the bottom surface of the container to complete the required calculated load (sand weighs approximately 110 pcf (50 kg/m 3 )). The dead load container(s) must be larger than the test specimen, but must not overhang the specimen by more than 1.5 in (38 mm). The dead load container(s) must be affixed so that it cannot move inside the perimeter of the test specimen during testing. The test specimen should not be fastened to the vibration table and should be allowed some lateral movement, yet restricted so that it does not move from under the perimeter of the dead load. (2)(b) When test units have large top surfaces, i.e., any dimension exceeding 18 in (0.46 m), the dead load must be subdivided into smaller portions. If only one dimension exceeds 18 in (0.46 m), the load must be divided into two equal portions along the longer dimension. If both dimensions exceed 18 in (0.46 m), the load must be divided into four equal portions, as shown in the diagram below. 2 Subsequent Tables in Item 181 would be renumbered as necessary. 3 Subsequent Notes in Item 181 would be renumbered as necessary. Subject 10, Page 3 of 8

54 SUBJECT 10 Proposed Classification Provisions Continued (3) Vibration Testing: Properly position either the identical shipping unit or the concentrated dead weight load on the shipping unit. Using procedure ASTM D4169 Schedule D, Truck Profile, Assurance Level II, for random vibration load, or procedure ASTM D4169 Schedule F for vertical-linear vibration under a stacked compressive load, test the shipping unit. Conduct the vibration testing on all three faces, except as noted below. Face 3 must be tested for one hour and Faces 4 and 6 must be tested for 30 minutes each, for a total duration of two hours. If the shipping unit is marked with upright arrow symbols, only Face 3 must be vibrated under the compressive load for two hours. Method (B) Separate Compressive Load/Vibration Testing Shipping units must be subjected to compression and vibration in separate tests. The compression test is conducted first and then the same shipping unit is vibration tested. (1) Compression Testing: Except as noted below, compression testing is required to be conducted on Faces 3, 4 and 6 of the same shipping unit, using either a machine compression test (per ASTM D642) or a constant load (dead weight) test (per ASTM D4577), see Table 3. When conducting compression tests, the size of the package changes with the three shipping orientations of the package, so the required concentrated forces or dead loads on the top of the package will change accordingly. Using the formulas below in Table 4 or 5, calculate the required force or load, depending upon which compression method is used, for each of the three faces, rounded up to the nearest 5 pounds force (lbf) or pounds (lbs), respectively. Apply the required compressive force or load on the shipping unit depending upon selected method found in Table 3. If the shipping container is marked with upright arrow symbols, only Face 3 should be compressed. Subject 10, Page 4 of 8

55 SUBJECT 10 Proposed Classification Provisions Continued Table 3: Compression Method Compression Type Length of Compression Compression Value Design Factor Time Designation (DF) Machine Compression Remove immediately once Test per ASTM D642 required force is reached FORCE 7 Constant Load (Dead Weight) Test per ASTM D hour/face LOAD 5 Table 4: Method (B) Force or Load Calculation Orientation Face 3 Down: 10 x (108 h) x (l x w) x DF FORCE or LOAD = 1728 Orientation Face 4 Down: 10 x (108 w) x (l x h) x DF FORCE or LOAD = 1728 Orientation Face 6 Down: 10 x (108 l) x (w x h) x DF FORCE or LOAD = 1728 Where: FORCE = or LOAD = 10 = pounds force (lbf) or pounds (lbs) average density of LTL freight (pcf) 108 = inside height of trailer (in) 1728 = conversion factor (in 3 /ft 3 ) h = height of shipping unit (in) l = length of shipping unit (in) w = width of shipping unit (in) DF = Design Factor from Table 3 Subject 10, Page 5 of 8

56 SUBJECT 10 Proposed Classification Provisions Concluded Table 5: Method (B) Force or Load Calculation (Metric) Orientation Face 3 Down: FORCE or LOAD = 162 x (2.7 h) x (l x w) x DF x 9.8 Orientation Face 4 Down: FORCE or LOAD = 162 x (2.7 w) x (l x h) x DF x 9.8 Orientation Face 6 Down: FORCE or LOAD = 162 x (2.7 l) x (w x h) x DF x 9.8 Where: FORCE = or LOAD = Newtons of force (Nf) or Newtons (N) average density of LTL freight 162 = (kg/m 3 ) 2.7 = inside height of trailer (m) h = height of shipping unit (m) l = length of shipping unit (m) w = width of shipping unit (m) DF = Design Factor from Table = metric conversion factor (m/s 2 ) NOTE 5 If the package weighs less than 30 lbs (14 kg) or is 2 ft 3 (0.056 m 3 ) or less in size, the factor is reduced to 54 in (1.4 m) instead of 108 in (2.7 m). NOTE 4 To avoid any gross distortion of calculated loads, a maximum dead load of 750 lbs (340 kg) should be utilized when the calculated dead load exceeds this limitation. NOTE 5 For step or form-fitting containers, the load may be applied proportionately, dividing the total load by the surface area of the panels formed by stepping. NOTE 8 When conducting a constant load compression test, load and maintain the Compression Dead Load for one hour. When conducting a machine compression test per ASTM D642, remove the force immediately after reaching a DF of 7.0. (2) Vibration Testing: Using the same shipping unit, conduct vibration testing on all three faces, except as noted below. Face 3 must be tested for one hour and Faces 4 and 6 must be tested for 30 minutes each, for a total duration of two hours, using any of the three following vibration methods. (a) Random Vibration, ASTM D4169 Schedule E, Truck Profile, Assurance Level II; (b) Repetitive Shock, ASTM D4169 Schedule F (vertical-linear motion); or (c) Repetitive Shock, ASTM D4169 Schedule F (rotary motion). If the shipping unit is marked with upright arrow symbols, only Face 3 should be vibrated for two hours. Sections III-VI No Change. Subject 10, Page 6 of 8

57 SUBJECT 10 Analysis Research Project 1126 This proposal is based on information developed during Research Project The project was initiated based on the discussion during the consideration of Subjects 1 and 2 of Docket (January, 2011), which were proposals submitted by a CCSB-registered third party package testing laboratory to amend Items (Rules) 180 and 181, respectively. In an effort to gain information regarding the current provisions of Item 181, possible provisions based on the Docket proposal were ed to all active CCSB-registered third party testing labs in March of Subsequent to that mailing, additional possible changes were brought forward and those provisions were ed to the labs in May of This proposal encompasses all of the information received to date. History of Provisions Due to the chronic damage problems that exist with the handling of furniture in the LTL environment, Item 181 was established to test the performance of packages for furniture and furniture parts. It provides an alternative to the packaging provisions found within the Furniture Group, item 79000, and the Furniture Parts Group, item 82750, the numbered F and S packages, Item 180 and the Test Shipment Permit Program. The rule first appeared in Supplement 5 to NMF 100-Z, effective July 22, 2000, as a result of action taken on Subject 19 of Docket (May, 2000), which was approved as docketed. Based on information developed during Research Project 1034, the CCSB docketed a proposal Docket , Subject 16 (October, 2009) to amend the rule in the interest of clarification and simplification. That proposal was approved as docketed, and the changes became effective on January 9, 2010 in Supplement 5 to NMF 100-AI. As part of that proposal, it was stated that, going forward, the CCSB would amend the rule, as needed, on a case-by-case basis to ensure it continues to be representative of the motor carrier environment. Docket , Subject 2 (January, 2011) was a packaging laboratory proposal to amend Item 181, Sections I and II. However, the proposal was approved as modified, as only the proposed changes to Section I were accepted, and the provisions first appeared in Supplement 1 to NMF 100-AK, effective April 16, About Item 181 Item 181 currently identifies the test specimen s orientation by planes, which are identified by axes, e.g. x, y and z. However, it is more common to identify the orientation of a package by the faces: Face 3 is the bottom of the package; Face 4 is the width of the package (narrow side); and Face 6 is the length of the package (wide side). While Item 181 currently provides a diagram for the test specimen orientation and nomenclature, it does not provide additional explanation about that orientation and nomenclature (as Item 180 now does). Subject 10, Page 7 of 8

58 SUBJECT 10 Section II, Compression/Vibration Test, provides the testing procedures for compression and vibration testing, and there are two alternate methods available: Method A and Method B. Method A currently requires the test specimen to be vibration tested while under compression in accordance with ASTM D4169 Schedule D, Assurance Level II, for a total of one hour (20 minutes in each of the three axes). The compression is accomplished by using a dead weight load to simulate miscellaneous freight loaded on top of the test specimen. The procedure details how to calculate the dead weight load and specifies the type of load apparatus that is required. Method B subjects the test specimen to compression and vibration testing separately. Compression testing may be conducted either in accordance with ASTM D642 for machine compression, or using a constant load (dead weight). The procedure currently requires the test specimen to be compression tested in all three axes except when the shipping unit is marked with upright arrow symbols. Vibration testing may be conducted using one of the following test procedures: random, ASTM D4169 Schedule E, Assurance Level II; repetitive shock, ASTM D4169 Schedule F (vertical-linear motion); or repetitive shock, ASTM D4169 Schedule F (rotary motion). Methods A and B currently require the duration of the vibration testing to be only one hour (20 minutes per axis). However, other truck-related vibration test procedures require two hours: one hour on Face 3 and 30 minutes each on Faces 4 and 6, or two hours on Face 3 when the shipping unit is marked with upright arrow symbols. Furthermore, both Methods require the same compression load to be used on all three faces during top load vibration tests, even though the size of the test specimen changes as the orientation changes, which can have a significant effect on the test results. Based on sample testing from a CCSBregistered lab, it has been found that if the load formula is not changed to reflect the differences in the package s size when conducting testing on Faces 6 or 4, Face 6 will experience a 41% larger load and Face 4 will experience a 24.6% larger load. Item 181 does not provide rounding increments for the required load or force, and one should be established to prevent any miscalculation. Based on a recommendation from a CCSB-registered lab, rounding up to the nearest five pounds (lbs) or pounds force (lbf) for Methods A and B would mitigate the chance of miscalculation. Relationship to CCSB Policies and Guidelines One of the best ways to determine if packaging is capable of sufficiently protecting the commodities being shipped is through laboratory testing, which accounts for the dynamics of the transportation environment. Package testing is continuously changing and improving based on research from many different sources. The information of record was received from active CCSB-registered third party testing laboratories, which have vast experience with numerous testing protocols. CCSB policies state the Classification s rules should be kept up-todate. Based on other truck-related testing procedures and the labs knowledge and experience in the industry, the proposed changes to Item 181 would improve the procedure while making it more consistent with other established testing procedures for the motor carrier environment. For these reasons, this proposal, as docketed, is in keeping with CCSB policies. Subject 10, Page 8 of 8

59 SUBJECT 11 Re: Item (Rule) 680, Secs. 1(a), 5 and 10(a) CCSB Contact: Erin N. Topper Telephone (703) topper@nmfta.org Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 680, Packing or Packaging General, to read as follows: ITEM 680 PACKING OR PACKAGING GENERAL General Sec. 1. (a) The separate descriptions of articles provide the minimum, acceptable packaging requirements, see Note 1. Numbered packages or other packaging provisions (other than 'DOT Specification Number' packages, for which, see DOT's hazardous materials regulations) are authorized for use only when item descriptions contain reference thereto. The definitions of or specifications for packaging requirements are provided in: (1) Items 200 through 299, (2) numbered packages and (3) Note references. The minimum requirements notwithstanding, articles must be tendered for shipment in such a manner as to withstand the normal rigors of the less-than-truckload environment. Whether or not part of the specific requirements, protective packing forms or other packaging materials must be used where necessary to afford adequate protection against damage to the articles being shipped. Articles or articles and necessary interior packing forms must reasonably occupy the full cubic capacity of the outer shipping container, see Notes 2, 3 and 4. Note 1 The term 'packaging requirements' as used in this Classification or in tariffs governed thereby means the provisions which specify: (1) the kinds or specifications of the containers, packages or other manner in which the articles shall be packed or protected for shipment, and (2) how the articles shall be packed or protected by or within such containers, packages or other manner. Notes 2-4 No Change. Secs. 1. (b)-4. No Change. Definition of the Term 'In Packages' Sec. 5. When the term 'in packages' is provided in connection with the separate descriptions of articles, such articles will be accepted for transportation in any container or in any other form tendered to carrier which will permit handling into or out of vehicles as units, providing such containers or tendered forms will render the transportation of freight reasonably safe and practicable so that it will withstand the normal rigors of the less-than-truckload environment. The term 'in packages' includes articles securely fastened to lift truck skids, pallets or platforms, or unitized quantities, but does not include articles 'in bulk,' 'loose,' 'on skids' or articles racked or braced in vehicles. Secs No Change. Subject 11, Page 1 of 2

60 SUBJECT 11 Proposed Classification Provisions Concluded Definition of 'Wrapped' Sec. 10. (a) When in the separate description of articles the word 'wrapped' is referred to as a form of exterior packaging, such articles must be enclosed or enfolded within packaging material which completely covers the article. Such wrappers must be securely fastened. This method of packaging must render the transportation of freight reasonably safe and practicable so that it will withstand the normal rigors of the less-than-truckload environment. Secs.10. (b)-13. No Change. Analysis and Relationship to CCSB Policies and Guidelines The packaging provisions in the NMFC are minimum, acceptable requirements intended to ensure that freight is adequately protected so as to withstand the normal rigors of the less-than-truckload environment. The current language in Secs. 1(a), 5 and 10(a) of Item (Rule) 680 is not as clear as it might be in this regard. CCSB policies state that rules in the NMFC are to be clear as to intent and otherwise up-to-date. This proposal, as docketed, would clarify and update the language in Secs. 1(a), 5 and 10(a) of Item 680, in keeping with CCSB policies. Subject 11, Page 2 of 2

61 SUBJECT 12 Re: Flashlights, Searchlights or Spotlights, hand held, with power supply cord CCSB Contact: Donald A. Newell Telephone (703) Shannon C. Allard (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class LAMPS OR LIGHTING GROUP: subject to item Flashlights, Searchlights or Spotlights, electric, hand held, with power supply cord, with or without complementary battery packs, see Note, item , in boxes NOTE Applies only on units which are designed to plug into battery packs or boat or vehicle cigarette lighter receptacles. Proposed Classification Provisions Item Description Class LAMPS OR LIGHTING GROUP: subject to item Flashlights, Searchlights or Spotlights, electric, hand held, with power supply cord, with or without complementary battery packs, see Note, item , in boxes NOTE Applies only on units which are designed to plug into battery packs or boat or vehicle power outlet receptacles. Analysis and Relationship to CCSB Policies and Guidelines The provisions of item and Note, item were established as a result of action taken on Subject 12 of Docket 851 (January 1985) 1 and appeared in Supplement 5 to NMF 100-L, effective August 10, These provisions have remained substantially unchanged to the present. Per Note, item , the provisions of item encompass only flashlights, searchlights or spotlights that plug into battery packs or boat or vehicle cigarette lighter receptacles. However, over time, cigarette lighter receptacles have evolved. These receptacles are no longer primarily used to power cigarette lighters but rather as power outlets for electronic devices. Thus, the term cigarette lighter receptacles is no longer used in common practice and has been replaced with power outlet receptacles. 1 The provisions had been previously established by action taken on Subject 6 of Docket 828 (November 1982), but they were subsequently canceled by Order of the former Interstate Commerce Commission in Docket No , Reclassification Procedures National Classification Committee, served May 17, Subject 12, Page 1 of 2

62 SUBJECT 12 CCSB policy calls for replacing outdated terminology in commodity descriptions with current terminology for clarification purposes. Eliminating this outdated language and updating the language to reflect current terminology would provide clarity and address interpretive concerns. Amending the Note, item , as proposed, would be in keeping with CCSB policy and precedent. Subject 12, Page 2 of 2

63 SUBJECT 13 Re: Front-pack Baby Carriers, including Slings or Wraps CCSB Contact: Allison L. Austin Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class TRUNKS, TRAVELING BAGS OR RELATED ARTICLES: subject to item Carrying Cases or Bags, viz.: Backpack Baby Carriers; [Other Articles Listed Not Involved.] In boxes, crates or Packages 826 or 2213, 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 or greater NOTE Not Involved. Proposed Classification Provisions Item Description Class TRUNKS, TRAVELING BAGS OR RELATED ARTICLES: subject to item Carrying Cases or Bags, viz.: Backpack or Front-pack Baby Carriers, including Slings or Wraps; [Other Articles Listed No Change.] In boxes, crates or Packages 826 or 2213, 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 or greater NOTE No Change. Subject 13, Page 1 of 2

64 SUBJECT 13 Analysis This proposal was docketed in response to an interpretation inquiry regarding the applicable provisions for front-pack baby carriers. Only backpack baby carriers are specifically listed under the provisions of item , which has resulted in confusion over the applicable provisions for similar products, shown in the examples below. Considering the general design and function of these types of on-the-body carriers to provide support in the carrying of children opinions have held item applicable. The provisions for backpack baby carriers and several other similar products (e.g. backpacks, and pack carriers, NOI) were consolidated into item as a result of action taken on Docket 928, Subject 10 (December 1992) and first appeared in Supplement 9 to NMF 100-S, effective February 27, On-the-body baby carriers allow the wearer to secure the child to the body for handsfree travel. They are typically constructed of a soft material and may or may not have a structured frame. Prominent styles of on-the-body baby carriers include backpack, front-pack, slings and wraps. Some products may convert from one style to another, such as from frontpack to backpack, depending on the desired carrying position of the wearer. Relationship to CCSB Policies and Guidelines CCSB clarification policy calls for amending classifications for commodities that are the source, or potential source, of interpretation disputes so as to avoid those disputes. Interpretation questions have arisen over the applicable provisions for front-pack baby carriers. While several similar types of on-the-body baby carriers exist in the market, and have historically been classified under the same provisions, only backpack baby carriers are specifically named within the Classification. Amending item by adding Front-pack Baby Carriers, including Slings or Wraps to the description would provide clarification and address the interpretive issues. This proposal, as docketed, would be in keeping with CCSB policy and precedent. Subject 13, Page 2 of 2