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

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1 Re: Stone Blocks, Pieces or Slabs Staff Contact: Erin N. Topper Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class GRAVEL OR STONE GROUP: subject to item Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone, coquina or cast stone, NOI, see Notes, items 90502, and 90504, in boxes or crates, see Notes, items and NOTE Provisions on cast stone apply only on products of hydraulic, masonry, mortar, natural or Portland cement with or without sand or aggregate, or on stone dust, chips or granules combined with not to exceed 25 percent of plastic binder NOTE Provisions also apply on granite, marble, limestone, sandstone, coquina or cast stone blocks, pieces or slabs represented as Furniture Tops, Fireplace Hearths, Signs or Grave Markers (Gravestones), other than figures, images or statuary. Provisions do not apply on cast or natural stone sink or bathroom vanity tops, as named in item , nor on cast or natural stone represented as facing, flooring, paving or promenade tile, or quarries, as named in item NOTE Consignor of import shipments of carved, honed, lettered, polished or traced natural stone or cast stone molded to simulate carved, honed, lettered, polished or traced natural stone must furnish a certification of inspection stating the condition of the contents of each shipment. Such inspection must be performed by agents mutually satisfactory to carrier and shipper NOTE The following departures from packing requirements are permitted for carved, honed, lettered, polished or traced natural stone or cast stone molded to simulate carved, honed, lettered, polished or traced natural stone: 1. Fiberboard boxes need not comply with the size and weight limits set forth in Item 222, Sec. 3, when gross weight exceeds 90 pounds. 2. Furniture tops may be shipped in Package 94F. 3. 5,000 pounds or more of slabs in one shipment may be accepted not boxed nor crated when so loaded on edge as to prevent falling or tipping, and so braced in vehicle as to prevent shifting NOTE Stone, other than carved, honed, lettered, polished or traced natural stone and other than cast stone molded to simulate carved, honed, lettered, polished or traced natural stone, may be shipped loose or in packages National Motor Freight Traffic Association, Inc. Subject 2, Page 1 of 10

2 Proposed Classification Provisions Item Description Class GRAVEL OR STONE GROUP: subject to item Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone, coquina or cast stone, NOI, see Notes, items 90502, and 90504: Sub 1 Mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks, see Notes, items A-NEW Sub 2 and B-NEW In boxes or crates, or on lift truck skids, pallets or platforms, other than as set forth in sub 1, see Notes, items and B-NEW NOTE No Change NOTE No Change NOTE No Change NOTE Furniture tops may be shipped in Package 94F NOTE Cancel; no further application. A-NEW NOTE Applies on stone blocks, pieces or slabs secured on lift truck skids, pallets or platforms or shipping carriers or racks in a diagonal or vertical orientation. B-NEW NOTE Stone blocks, pieces or slabs tendered for shipment on lift truck skids, pallets or platforms or on shipping carriers or racks must be securely fastened to and must not overhang the edges of the lift truck skid, pallet or platform deck or shipping carrier or rack. Exposed surfaces and edges must be completely wrapped with plastic film or corrugated fiberboard or protected by wood or similar material. Analysis This proposal is based on information developed through Research Project 1122, which was initiated in November of 2010 based on reports that shipments of stone blocks, pieces or slabs, as named in item 90500, specifically when tendered on A-frame shipping racks, exhibit transportation characteristics inconsistent with the currently assigned class 50. Research Project 1122 During the course of the project, 568 potential shippers or manufacturers and 11 associations believed to represent those shippers or manufacturers were mailed questionnaires in February and May of Twenty-three companies responded that they ship these products via less-than-truckload (LTL) motor carrier, but only 12 of the 23 responses contained useable information. Responses were received from 26 companies who stated they do not ship or manufacture stone. Of the associations contacted, one association responded that their membership does not ship or manufacture these products, and one letter went unclaimed. Subject 2, Page 2 of National Motor Freight Traffic Association, Inc.

3 History of Provisions Provisions for cast or natural stone blocks, pieces or slabs were adopted from the rails in 1936 and first appeared in LTL-1. The provisions have been amended over the years in the interest of clarification, and various amendments have been made to attendant Notes and packaging requirements. The most recent significant change occurred as a result of action taken on Docket 963, Subject 2 (August, 1996), where multiple items were canceled and consolidated into item Concurrently, Notes referenced by those canceled items were also canceled and reestablished or consolidated into the current Notes, items 90502, 90503, and 90506, and Note, item was established. Those changes first appeared in Supplement 3 to NMF 100-W, effective October 19, Then as a result of action taken on Docket , Subject 23 (February, 2006) the minimum packaging requirements specified in item were amended to simply state in boxes or crates for clarification purposes. The change first appeared in Supplement 3 to NMF 100-AF, effective April 29, About Stone Blocks, Pieces or Slabs Item is the catchall classification for stone blocks, pieces or slabs made from granite, marble, limestone, sandstone, coquina or cast stone, and includes those represented as furniture tops, fireplace hearths, signs or gravestones. The item does not, however, apply on stone figures, images, statuary, sinks, bathroom vanity tops, or facing, flooring, paving or promenade tile, as those articles are named elsewhere in the Classification National Motor Freight Traffic Association, Inc. Subject 2, Page 3 of 10

4 Shipments of Stone Blocks, Pieces or Slabs Stone blocks, pieces or slabs may be shipped in boxes or crates, but are generally shipped on lift truck skids, pallets or platforms or on shipping carriers or racks (hereinafter referred to as pallets ), often mounted diagonally or vertically, i.e. on edge. The shipments may contain single or multiple blocks, pieces or slabs, which when not tendered boxed or crated may or may not be covered with fiberboard, plastic film or wood. The pallets are generally built long enough to support the entire block(s), piece(s) or slab(s), but sometimes the freight may overhang the pallet. Subject 2, Page 4 of National Motor Freight Traffic Association, Inc.

5 2011 National Motor Freight Traffic Association, Inc. Subject 2, Page 5 of 10

6 % of Figures in Interval CCSB DOCKET Transportation Characteristics Density The information of record includes 1,014 shipment observations submitted by shippers and carriers, and obtained during CCSB dock surveys. The densities range from 1.27 to pcf, with an average density of pcf. The overall frequency distribution is shown below. Overall Frequency Distribution 30% 22% 21% 20% 10% 0% 0% 0% 10% 12% 5% 8% 12% 4% 5% Density Intervals (pcf) Subject 2, Page 6 of National Motor Freight Traffic Association, Inc.

7 % of Figures in Interval % of Figures in Interval CCSB DOCKET Stone blocks, pieces or slabs tendered in boxes or crates or flat on pallets range in density from 3.37 to pcf, with an average density of pcf, and 78% of the figures are 30 pcf or greater as shown in the frequency distribution below. Not Mounted Diagonally or Vertically 80% 78% 60% 40% 20% 0% 0% 0% 2% 0% 0% 2% 5% 0% 5% 7% Density Intervals (pcf) Stone blocks, pieces or slabs mounted diagonally or vertically on pallets range in density from 1.27 to pcf, with an average of 9.89 pcf. The frequency distribution below shows the figures are spread throughout the range. Mounted Diagonally or Vertically 30% 23% 22% 20% 10% 0% 0% 0% 11% 12% 5% 9% 12% 4% 2% Density Intervals (pcf) 2011 National Motor Freight Traffic Association, Inc. Subject 2, Page 7 of 10

8 % of Figures in Interval CCSB DOCKET Stowability Stone blocks, pieces or slabs will likely require floor loading due to the weight. When tendered in boxes or crates or flat on pallets, the freight will generally provide a regular load-bearing surface, although some handling units are marked with shippers instructions, Do Not Double Stack. The information of record shows that while many of these handling units do not exceed 96 inches in length, some do. Handling units that exceed 96 inches in length present additional stowing considerations. Stone blocks, pieces or slabs mounted diagonally or vertically on pallets are more difficult to stow than general packaged freight. Due to the configuration and size of the handling units, carriers are restricted to floor loading, and they may have difficulty loading other shipments around these products, as there is no lateral support for adjacent freight. The length of these handling units ranges from 44 to 165 inches, with an average of inches (10.23 feet). Carriers are unable to stack freight on these handling units due to the lack of a flat load-bearing surface. The lack of a load-bearing surface can significantly impact the loaded density. When 96 inches is assumed as the inside height of the vehicle, the loaded density ranges from 0.82 to pcf, with an average of 6.44 pcf. As can be seen from the frequency distribution below, the density range, while still wide, is clustered more toward the lower end of the density scale, with 74% of the figures falling between 2 and 8 pcf. Mounted Diagonally or Vertically - Loaded Density 40% 30% 37% 27% 20% 10% 0% 0% 2% 10% 7% 8% 4% 4% 1% 0% Density Intervals (pcf) Handling Extra care and attention is necessary when handling stone blocks, pieces or slabs, as evidenced by the precautionary markings, Fragile, Handle with Care, Must Use Fork Extensions, and This End Up. When the length exceeds 96 inches, additional equipment, such as fork extensions, or additional personnel may be necessary to safely handle the freight. Subject 2, Page 8 of National Motor Freight Traffic Association, Inc.

9 Liability Stone blocks, pieces or slabs are susceptible to damage, particularly when not in boxes or crates or not adequately protected by packaging materials, such as fiberboard or wood. In some instances, the stone may overhang the pallet, which could leave portions of the stone exposed to damage. Many shipments are labeled with instructions to the consignee to inspect the freight for damage before accepting the shipment or are labeled High Claim Value. Two shippers report they have claims on four shipments per year, while seven shippers report two claims or fewer per year. Although one carrier no longer handles this freight due to high claims ratios, other carriers did not indicate a significant claims problem. The value per pound ranges from $0.04 to $5.71, with an average of $0.41 per pound. Notes, Items and Notes, items and provide packaging exceptions. Note, item permits carved, honed, lettered, polished or traced natural stone or cast stone molded to simulate carved, honed, lettered, polished or traced natural stone to be shipped in fiberboard boxes not complying with the size and weight limits set forth in Item 222 when the gross weight exceeds 90 pounds, and it also permits shipments of 5,000 pounds or more to be loaded on edge without being boxed or crated when tendered so as to prevent falling or tipping, and are braced in the vehicle to prevent shifting. Note, item permits stone, other than carved, honed, etc., to be shipped simply loose or in packages. None of these forms of tender would adequately protect the freight in transit and may cause negative stowing, handling and liability considerations. Relationship to CCSB Policies and Guidelines Research Project 1122 was initiated to determine the current transportation characteristics of stone blocks, pieces or slabs, particularly when tendered for shipment mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks. It had been reported that much of this freight exhibits transportation characteristics inconsistent with the currently assigned class 50. The information of record includes 1,014 shipment observations, which range in density from 1.27 to pcf, with an average density of pcf. When that data is segregated by manner of tender, stone blocks, pieces or slabs tendered in boxes or crates or flat on pallets range in density from 3.37 to pcf, with an average density of pcf. An average density of pcf is generally associated with a class 50, which calls for a minimum average density of 50 pcf. However, stone blocks, pieces or slabs are inherently liable to damage, particularly when not in boxes or crates or not adequately protected by packaging materials. In this respect, some handling units have precautionary markings or instructions, such as Fragile, Handle with Care, Must Use Fork Extensions, This End Up and Do Not Double Stack. This will impact stowability and handling regardless if the stone is tendered flat or on edge. In fact, it could be argued that shipping stone on edge, i.e. mounted diagonally or vertically, reduces liability risk, and therefore, improves handling National Motor Freight Traffic Association, Inc. Subject 2, Page 9 of 10

10 Due to the configuration and size of the handling units when stone blocks, pieces or slabs are mounted diagonally or vertically on pallets, carriers are restricted to floor loading, and they may have difficulty structuring the load due to the lack of lateral support for other freight. In addition, the handling units do not provide a flat load-bearing surface, which affects the loaded density. When the data is evaluated using 96 inches as the inside height of the vehicle, the loaded density ranges from 0.82 to pcf, with an average of 6.44 pcf. An average density of 6.44 pcf is generally associated with a class 150, which under CCSB guidelines calls for a minimum average density of 6 pcf. CCSB policies state that classification provisions should reflect a commodity s transportation characteristics, and the packaging specifications should ensure that freight is adequately protected in the motor carrier environment. Based on the information of record, it would be in keeping with CCSB policies to amend item to provide for stone blocks, pieces or slabs when mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks at a class 150, based on the average loaded density of 6.44 pcf. A class 55, one class higher than that called for under CCSB density guidelines for the average density of pcf, would be assigned to stone tendered in boxes or crates or flat on lift truck skids, pallets or platforms, in view of the stowability, handling and liability considerations. Distinguishing between stone blocks, pieces or slabs mounted diagonally or vertically for shipment and those that are not would also be in keeping with classification precedent. For instance, item assigns a higher class to steel tank heads (ends) shipped on Aframe or easel-type shipping racks than those not so tendered, in consideration of their respective transportation characteristics. The provisions are the result of action taken on Docket , Subject 16 (November, 2000) and first appeared in Supplement 2 to NMF 100- AA, effective January 27, Two new Notes would be added and referenced by item The first would further define Mounted diagonally or vertically on lift truck skids, pallets or platforms or on shipping carriers or racks. The second would provide additional packaging requirements for stone tendered on lift truck skids, pallets or platforms or on shipping carriers or racks by specifying the stone must be securely fastened to and must not overhang the edges of the lift truck skid, pallet or platform deck or shipping carrier or rack, and must have exposed surfaces and edges completely wrapped with plastic film or corrugated fiberboard or protected by wood or similar material. Finally, Note, item 90506, which specifies packaging exceptions beyond what is required by the item, would be amended to only permit stone represented as furniture tops to be shipped in Package 94F. Note, item 90507, which allows certain types of stone to be tendered loose or in packages, would be canceled as having no further application. This proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 2, Page 10 of National Motor Freight Traffic Association, Inc.

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