Staff Contact: Erin N. Topper Telephone (703)

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1 Re: Item (Rule) 180, Performance Testing of Shipping Containers Staff Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Proposed Classification Provisions It is proposed to amend Item (Rule) 180, Performance Testing of Shipping Containers, to read as follows: ITEM 180 PERFORMANCE TESTING OF SHIPPING CONTAINERS [Introductory Paragraphs No Change.] Orientation and Nomenclature for Test Specimens Consisting of a Shipping Container without Lift Truck Skid or Pallet Outside Base: For test specimens consisting of a shipping container not on or not having a lift truck skid or pallet outside base, 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 National Motor Freight Traffic Association, Inc. Subject 11, Page 1 of 11

2 Orientation and Nomenclature for Test Specimens with Lift Truck Skid or Pallet Outside Base: For test specimens consisting of one or more shipping containers on or having a lift truck skid or pallet outside base, place the shipping unit in its normal shipping orientation with the front facing forward. Use the diagram below to determine the dimensions of the product(s), and the overall dimensions of the shipping unit. PERFORMANCE TEST REQUIREMENTS: All applicable shipping units must be tested as follows: No Change. Section I. Conditioning 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 has a lift truck skid or pallet outside base, or is marked with upright arrow symbols, the container must be tested on Faces 3, 4 and 6. If the shipping unit has either a lift truck skid or pallet outside base, 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. If the shipping unit is 6 ft (1.83 m) or taller in height, and has a lift truck skid or pallet outside base, the compressive load or force requirements in Methods (A) and (B) 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 to the nearest 5 pounds (lbs), from the formulas in Table 1 or 2: Subject 11, Page 2 of National Motor Freight Traffic Association, Inc.

3 Table 1: Method (A) Load Calculation Orientation Face 3 Down: 10 x (108 h) x (l x w) LOAD = Orientation Face 4 Down: 10 x (108 w) x (l x h) LOAD = Orientation Face 6 Down: 10 x (108 l) x (w x h) LOAD = Where: LOAD = pounds (lbs) average density of LTL freight 10 = (pcf) inside height of trailer (in), see 108 = Note 2 = conversion factor (in 3 /ft 3 ) height of product(s) or shipping h = unit (in) l = length of product(s) (in) w = width of product(s) (in) Table 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 ) inside height of trailer (m), see 2.7 = Note 2 height of product(s) or shipping h = unit (m) l = length of product(s) (m) w = width of product(s) (m) 9.8 = metric conversion factor (m/s 2 ) 2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 3 of 11

4 NOTE 2 No Change. (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. (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, Assurance Level II, for random 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 has either a lift truck skid or pallet outside base or is marked with upright arrow symbols, only Face 3 must be vibrated under the compressive load for two hours. Subject 11, Page 4 of National Motor Freight Traffic Association, Inc.

5 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 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 has a lift truck skid or pallet outside base, or is marked with upright arrow symbols, only Face 3 should be compressed. Table 3 1 : Compression Method Compression Type Machine Compression Test per ASTM D642 Constant Load (Dead Weight) Test per ASTM D4577 Length of Compression Time Remove immediately once required force is reached Compression Value Designation FORCE 1 hour/face LOAD 1 Subsequent Tables in Item 180 would be renumbered as necessary National Motor Freight Traffic Association, Inc. Subject 11, Page 5 of 11

6 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 = Orientation Face 4 Down: 10 x (108 w) x (l x h) x DF FORCE or LOAD = Orientation Face 6 Down: 10 x (108 l) x (w x h) x DF FORCE or LOAD = Where: FORCE = or LOAD = pounds force (lbf) or pounds (lbs) average density of LTL freight 10 = (pcf) inside height of trailer (in), see 108 = Note 3 = conversion factor (in 3 /ft 3 ) height of product(s) or shipping h = unit (in) l = length of product(s) (in) w = width of product(s) (in) DF = Design Factor from Table 6 Subject 11, Page 6 of National Motor Freight Traffic Association, Inc.

7 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 = 162 = Newtons of force (Nf) or Newtons (N) average density of LTL freight (kg/m 3 ) inside height of trailer (m), see 2.7 = Note 3 height of product(s) or shipping h = unit (m) l = length of product(s) (m) w = width of product(s) (m) DF = Design Factor from Table = metric conversion factor (m/s 2 ) NOTE 3 No Change National Motor Freight Traffic Association, Inc. Subject 11, Page 7 of 11

8 Proposed Classification Provisions Concluded Table 6: Design Factor Shipping Unit Construction (a) A corrugated fiberboard or plastic container that may or may not have stress-bearing interior packaging using these materials, and where the product does not support any of the load. An example is a plastic bottled product in a corrugated box with a corrugated interior packing. (b) A corrugated fiberboard or plastic container that has stress-bearing interior packaging with rigid inserts such as wood. An example is an appliance packed in a corrugated box with wood-reinforced corner posts. (c) A container constructed of materials other than fiberboard or plastic that are not temperature or humidity sensitive or where the product supports the load directly. An example is a wood crate or box. Design Factor (DF) Machine Compression Dead Weight ASTM D642 ASTM D , see Note 4 5.3, see Note NOTE 4 2 When testing fiberboard containers that have been conditioned to 40 F (4 C) and 85% RH or 100 F (38 C) and 85% RH, the Design Factor should be reduced by 50%. (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, see Note 5: (a) Random Vibration, ASTM D4169 Schedule E 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 has a lift truck skid or pallet outside base, or is marked with upright arrow symbols, only Face 3 should be vibrated under the compressive load for two hours. NOTE 5 For high or unstable shipping units, random or vertical-linear tests may be preferred. [Sections III-VII No Change.] 2 Subsequent Notes in Item 180 would be renumbered as necessary. Subject 11, Page 8 of National Motor Freight Traffic Association, Inc.

9 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 180, Section II, possible provisions based on the Docket proposal were ed to all active CCSBregistered third party testing labs in July of Subsequent to that mailing, additional possible changes were brought forward and those provisions were ed to the labs in December of This proposal encompasses all of the information received to date. History of Provisions Item (Rule) 180 first appeared in Supplement 10 to NMF 100-U, effective January 21, 1995, as a result of action taken on Subject 19 of Docket 945 (August, 1994), which was approved as modified. This rule was developed by a committee of packaging professionals consisting of representatives from NMFTA, ISTA and IoPP in order to establish a performance testing procedure for shipping containers that will be subjected to the less-than-truckload (LTL) environment. This procedure consists of compression, vibration, impact, handling and environmental tests used to simulate the conditions shipping containers are exposed to. Initially, this rule was put into effect for three years it was set to expire on January 21, 1998 in order to determine if it was beneficial to shippers and carriers. Since then the rule has been made permanent, and over the last 10 years, a number of amendments have been made in order to incorporate updated standards and to clarify terminology or procedures. As a result of action taken on Docket , Subject 15 (October, 2009), the rule was updated in the interest of clarification and simplification, and that proposal was approved as docketed. The changes became effective on January 9, As part of that proposal, it was stated that, going forward, the CCSB would amend the rule, as needed, on a case-bycase basis to ensure it continues to be representative of the motor carrier environment. Docket , Subject 1 (January, 2011) was a packaging laboratory proposal to amend Item 180, 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, National Motor Freight Traffic Association, Inc. Subject 11, Page 9 of 11

10 About Item 180 Item 180 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). Additionally, the dimensions of a test specimen change when the article is tendered on a lift truck skid or pallet outside base. Item 180 does not currently define the orientation or nomenclature of the test specimen. 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 planes). 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 in accordance with ASTM D642 for machine compression or ASTM D4577 for constant load (dead weight). The procedure currently requires the test specimen to be compression tested in all three planes, even when the shipping unit has a lift truck skid or pallet base. Vibration testing may be conducted using one of the following test procedures: random, ASTM D4169 Schedule E Level II; repetitive shock, ASTM D4169 Schedule F (vertical-linear motion); or repetitive shock, ASTM D4169 Schedule F (rotary motion) for a total of one hour. Unlike Method A, Method B uses design factors in the calculation of the load or force required for compression testing, based on the type of packaging utilized. It has been reported that when the products are tendered in fiberboard containers and conditioned at high humidity, the compression of the fiberboard is approximately 50% of the compression under ambient conditions (73ºF and 50% RH). Therefore, it was found that the current design factors are excessive when conducting machine or dead weight compression testing under high humidity conditioning levels. Methods A and B currently require the duration of the vibration testing to be only one hour (20 minutes per plane). 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 has a lift truck skid or pallet base, or 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 CCSB-registered 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. Subject 11, Page 10 of National Motor Freight Traffic Association, Inc.

11 Item 180 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, a rounding increment of five pounds (lbs) or pounds force (lbf) for Methods A and B, is proposed. 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, and as such, they have vast experience with numerous testing protocols. CCSB policies state the Classification s rules should be kept up-to-date. Based on other truck-related testing procedures and the labs knowledge and experience in the industry, the proposed changes to Section II of Item 180 would improve the procedure while making it more consistent with other established testing procedures for the motor carrier environment. For these reasons, the proposal, as docketed, is in keeping with CCSB policies National Motor Freight Traffic Association, Inc. Subject 11, Page 11 of 11