CCSB Contact: Daniel E. Horning Telephone (703) Item Description Class

Transcription

1 Re: Bucks, Casings or Frames, door, metal or wood CCSB Contact: Daniel E. Horning Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING METALWORK GROUP: subject to item Bucks or Frames, door, steel, fabricated from bars, plates or shapes 3 /16 inch or thicker Casings or Frames, door, iron or steel, or wood covered with iron or steel or tin plate: Sub 2 KD Casings or Frames, door, brass, bronze, copper or nickel-silver, or metal or wood covered with brass, bronze, copper or nickel-silver, in boxes or crates: Sub 2 KD Frames, door, NOI, aluminum or aluminum and iron or steel combined: Sub 1 SU, in boxes or crates Sub 2 KD, in boxes, or in tubes with closed ends BUILDING WOODWORK GROUP: subject to item NOTE Where reference is made to this note, provisions apply on articles of foreign wood, other than Canadian wood or other than foreign birch, pine or spruce, not further finished than primed NOTE Where reference is made to this note, provisions apply on articles of native wood, Canadian wood or foreign birch, pine or spruce, not further finished than primed NOTE Where reference is made to this note, provisions apply on articles further finished than primed or wholly or partially covered with plastic other than laminated plastic Frames, door, see Note, item 37502, in boxes or crates: Sub 2 KD Frames, door, see Note, item 37506, in boxes or crates: Sub 2 KD Frames, door, NOI, see Note, item 37504, with or without weatherstrips and with or without plastic sill tracks: Sub 2 KD, in packages National Motor Freight Traffic Association, Inc. Subject 5, Page 1 of 7

2 Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item NEW Bucks, Casings or Frames, door, NOI, metal or wood, with or without components of other materials: Sub 1 In boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 6 but less than Sub 4 12 or greater Sub 5 In packages other than boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than Sub 7 6 but less than Sub 8 12 or greater BUILDING METALWORK GROUP: subject to item Bucks or Frames, door, steel, fabricated from bars, plates or shapes 3 /16 inch or thicker... Cancel; see Casings or Frames, door, iron or steel, or wood covered with iron or steel or tin plate, etc... Cancel; see Casings or Frames, door, brass, bronze, copper or nickel-silver, or metal or wood covered with brass, bronze, copper or nickel-silver, etc... Cancel; see Frames, door, NOI, aluminum or aluminum and iron or steel combined, etc... Cancel; see BUILDING WOODWORK GROUP: subject to item NOTE No Change NOTE No Change NOTE No Change Frames, door, see Note, item 37502, etc... Cancel; see Frames, door, see Note, item 37506, etc... Cancel; see Frames, door, NOI, see Note, item 37504, with or without weatherstrips and with or without plastic sill tracks, etc... Cancel; see Subject 5, Page 2 of National Motor Freight Traffic Association, Inc.

3 Analysis Research Project 1213 This proposal is based on information developed through Research Project 1213, which was initiated in December 2013 to address interpretation issues and investigate the transportation characteristics of door casings or frames. During the project, questionnaires were sent to 77 potential manufacturers or shippers and 11 trade associations related to the door frame industry. Mailings were sent in November 2014, and for non-respondents, a second, follow-up letter was sent in January From those questionnaires, usable information was received from six companies, while one returned questionnaire did not contain usable information. One other company responded indicating they do not manufacture or ship the involved commodities. There were no responses received from any of the associations. Additional information was developed through CCSB dock surveys, the CCSB s Density Study 1 and carrier-submitted reports. History of Provisions The original provisions of the involved items were largely adopted from the rails and first appeared in LTL-1, effective April 1, Over the years, there have been description amendments and clarification revisions. Some class adjustments 2 occurred with the conversion to NMFC A-1, effective July 10, The current classes in items 35960, and applying on metal units were established as a result of action taken on Docket 715, Subject 4 (September 1971). Information of record indicated a density range from 3.5 to 10 pcf, with averages between 5.5 and 6.0 pcf, for steel units. The value was reported at $0.40 per pound (in 1971 dollars). Likewise, a similar class was assigned for brass, bronze or copper units due to the competitive nature of the commodities. (Competition with other commodities and trade conditions are no longer considered appropriate transportation elements in evaluating commodities.) The class 150 for aluminum units was considered reflective of densities ranging from 2.0 to 4.5 pcf. Poor loading, stowing and handling characteristics were other factors cited in the record. These changes first appeared in Supplement 4 to NMF 100, effective March 2, (No explanation or justification could be found through docket research - perhaps due to the antiquity of the item provisions - relating to the inconsistent use of the terms bucks, casings and frames ; however, an industry review has confirmed that all are relevant and used in current trade parlance. Likewise, the packaging requirements are inconsistent, if they exist at all.) 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 See Special Docket No. 1 (issued July 20, 1949), pertaining to steel bucks, frames or casings as well as brass, bronze, copper or nickel-silver casings or frames National Motor Freight Traffic Association, Inc. Subject 5, Page 3 of 7

4 About Door Bucks, Casings or Frames Door bucks, casings or frames are building components that provide for the rough opening and structure into which doors will be installed. Frames used in residential buildings are typically made from wood, while those found in commercial structures are usually metal. Irrespective of use or material, the central purpose is to provide an enclosure or support for the door. Product depictions are provided below. Door Buck Door Frame Door Casing Transportation Characteristics Density The information of record includes 6,410 figures, exhibiting a range in density from 0.26 to pcf, for an average density of pcf. As the frequency distribution below shows, the densities are distributed throughout the range, but the data can be divided into three density groupings of less than 6 pcf, 6 but less than 12 pcf, and 12 pcf or greater. Frequency Distribution % of Figures in Interval 15.00% 10.00% 5.00% 0.00% 3.73% 5.13% 13.20% 14.38% 10.30% 8.38% 7.77% 14.88% 14.56% 4.46% 3.21% Density Intervals (pcf) When the data is evaluated on the basis of the three proposed density groupings, the ranges and averages are calculated as shown in the table on the following page. Subject 5, Page 4 of National Motor Freight Traffic Association, Inc.

5 Density Group (pcf) Density Range (pcf) Average Density (pcf) Less than but less than or greater Handling Bucks, casings or frames are generally shipped in boxes or crates, or banded or wrapped in plastic or fiberboard on lift truck skids or pallets. Those tendered in boxes may or may not be unitized on lift truck skids or pallets. When secured on lift truck skids or pallets, the articles may be either vertically oriented, mounted on edge or placed flat. Shipper instructions may include such notices as Careful Loading Forks Will Damage This Freight or Use No Fork Lifts, greatly limiting the carrier s ability to handle the freight in an efficient and timely manner. One carrier reports that this type of freight can be hard to handle in the LTL environment as handling units can be 8 feet or longer. Due to the length and configuration of these units, negative handling considerations exist regardless of the method of packaging. Stowability When tendered in an upright position or without protective packaging on lift truck skids or pallets, articles may be more difficult to stow than general boxed freight. Carriers may be restricted to floor loading and are not able to stack freight on top due to the lack of a flat load-bearing surface. Some shipments are labeled with precautionary markings or instructions such as Do Not Double Stack, with warning cones, among others 3. The configuration of the handling units has a significant impact on the carrier s ability to safely stow this freight, even when tendered in boxes or crates. Pictures of the involved products as tendered for shipment are shown below. 3 Other labels that have been observed include Do Not Lay Flat, This Side Up, Do Not Tilt and Fragile Handle With Care National Motor Freight Traffic Association, Inc. Subject 5, Page 5 of 7

6 Liability These commodities are not perishable, susceptible to theft nor are they hazardous in nature. They may be liable to damage during transit when tendered in packages other than boxes or crates and not adequately protected by packaging. Bucks, casings or frames may also damage other freight with which stowed as they often have sharp edges. One carrier, for three separate accounts reports claims ratios of 22.8%, 6.52% and 1.5% for both damage and shortages. A second carrier has documented claims involving NMFC items 35960, and 35760, and reports ratios of 0.14%, 0.26% and 0.34%, respectively. A third carrier reports a yearto-date claims ratio of 8.85%, where one shipper filed 31 damage claims totaling $10, The carrier reports that they are no longer handling this account due to poor packaging. Shippers who returned the commodity questionnaires report damage claims as low as two or three per year, while others report incidents as high as 12 to 15 per year (or alternatively expressed as 3% per year). The value per pound ranges from $0.84 to $2.81, for an average of $1.74 per pound. Relationship to CCSB Policies and Guidelines CCSB policies call for combining item descriptions embracing related commodities, structuring item descriptions so as to foster clarification and simplification, and providing uniformity in provisions addressing the same or similar circumstances. Therefore, it would be in keeping with CCSB policy, as proposed, to cancel the individual classifications for metal or wood door bucks, casings or frames, with reference to a new item under the Building Materials, Miscellaneous, Group. In addition, there is no evidence to suggest that bucks, casings or frames as embraced under the Building Woodwork Group are restricted to a specific type of wood or not further finished than primed. Therefore, eliminating the references to Notes, items 37502, and 37506, which restrict application to origin of wood and degree of finishing, would be consistent with CCSB clarification policies. CCSB policy also calls for provisions to reflect a commodity s known transportation characteristics. Information of record indicates that bucks, casings or frames are shipped in a variety of different configurations (vertically, flat or on edge) and packaging. The information of record ranges in density from 0.26 to pcf, with an average density of pcf. CCSB policy further provides that where commodities or commodity groups exhibit a wide range in density not accurately reflected by a single, overall average density, they may be assigned density-based classes. However, research has identified several significant negative handling, stowability and liability considerations that must also be considered, in accordance with CCSB policies. These have been detailed in the Analysis section and include factors such as floor loading requirements, prohibitions on double stacking, and damage claims. Additionally, CCSB policies state that packaging specifications should be established, as necessary, to ensure that freight is adequately protected in the motor carrier environment. The current provisions governing bucks, casings or frames, in many instances, do not contain any minimum packaging requirements. Therefore, it would be in keeping with CCSB packaging policies to require the articles to be shipped either in boxes or crates or in other packages. Subject 5, Page 6 of National Motor Freight Traffic Association, Inc.

7 In view of the information of record, it would be in keeping with CCSB policy and classification precedent to establish provisions based on packaging and density, as proposed 4. As detailed in the discussion of density, the density figures are distributed in three clusters or groupings of less than 6 pcf, 6 but less than 12 pcf, and 12 pcf or greater. The following table provides an evaluation of the density information of record on the basis of the three proposed density groups and shows the average density associated with each group, the class according to CCSB density guidelines, and the class adjustments to reflect the identified negative handling, stowing and liability considerations when packaged in boxes or crates, or in packages other than boxes or crates. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines One-Class Adjustment Based on Handling and Stowability Considerations Two-Class Adjustment Based on Handling, Stowability and Liability Considerations Less than but less than or greater With respect to commodities that exhibit less-than-favorable handling, stowability or liability characteristics, there is CCSB precedent for assigning a one-class adjustment for those commodities in boxes or crates and a two-class adjustment for those in packages other than boxes or crates than what would normally be called for under the density guidelines. A similar approach was taken on Docket , Subject 22 (June 2008), involving doors, NOI, other than rolling, as named in item In that instance, the CCSB approved provisions based on packaging and density. Doors tendered in boxes, crates or other specified packaging were subject to a one-class adjustment, while doors tendered in packages other than boxes, crates or the specified packaging were subject to a two-class adjustment to reflect the identified negative handling, stowing and liability characteristics. Based on the information of record, this proposal, as docketed, is consistent with CCSB policy and precedent. 4 The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 5, Page 7 of 7