Re: Electrical Switch Boxes, Enclosures, Outlet Boxes or Outlet Box Covers, or Junction Boxes or Cabinets, steel Item 63170

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1 Re: Electrical Switch Boxes, Enclosures, Outlet Boxes or Outlet Box Covers, or Junction Boxes or Cabinets, steel Item Staff Contact: William F. Mascaro Telephone (703) Allison L. Austin (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item NOTE Applies only on articles named when without electrical equipment such as switches or receptacles Switch Boxes or Electrical Enclosures, NOI, with or without covers, with or than outlet box plates; other than steel, see Note, item 63162, in boxes, see Note, item 63161, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE Not Involved NOTE Not Involved Switch Boxes or Electrical Enclosures, NOI, with or without covers, with or than outlet box plates; steel, see Note, item 63171, in packages, see Note, item NOTE Provisions apply only on the articles named when manufactured solely of steel. For provisions applicable on articles having components of other materials, see item NOTE Steel junction boxes or cabinets may be shipped loose National Motor Freight Traffic Association, Inc. Subject 2, Page 1 of 6

2 Proposed Classification Provisions Item Description Class ELECTRICAL EQUIPMENT GROUP: subject to item NOTE No Change Switch Boxes or Electrical Enclosures, NOI, with or without covers, with or than outlet box plates; see Note, item 63162, in boxes, see Note, item 63161, 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 No Change NOTE No Change Switch Boxes or Electrical Enclosures, NOI, with or without covers, with or than outlet box plates; steel, etc.... Cancel; see item NOTE Cancel; no further application NOTE Cancel; no further application. Analysis Research Project 1135 This proposal is based on information developed through Research Project 1135, which was initiated by the CCSB in July 2011 in response to indications that the current classification provisions of item 63170, for steel switch boxes or electrical enclosures, conduit outlet boxes or junction boxes or cabinets, or outlet box covers, might not be reflective of the commodities transportation characteristics. In September, and for those that did not respond, in November of 2011, 329 potential manufacturers or shippers, and five trade associations believed to represent those companies, were sent commodity questionnaires. Of the companies contacted, 18 responded that they do not manufacture or ship these articles, two companies indicated that they do not ship via less-than-truckload (LTL), and 15 companies provided Subject 2, Page 2 of National Motor Freight Traffic Association, Inc.

3 information; however, not all the information was usable. Of the five associations contacted, the National Electrical Manufacturers Association (NEMA) responded and agreed to forward the questionnaire to its membership. Additional information of record for this proposal was developed through carrier-submitted Shipment Information Forms and the CCSB s Density Study 1. History of Provisions Docket , Subject 8 (May 2003) sought to amend the provisions of item to provide density-based classes on electrical enclosures of all material consists. Interested shippers objected to the inclusion of steel-fabricated electrical enclosures in the density-based provisions. In light of this shipper opposition, consideration of that proposal was referred to the next meeting. At the subsequent meeting, the density-based provisions were approved as modified. However, the effective date was extended to give interested shippers sufficient time to draft a counterproposal and have it considered before the changes would take effect. In response, interested shippers docketed a proposal Docket , Subject 18 (November 2003) that would establish a new item for steel electrical enclosures at a class 70, and concurrently amend item to provide the density-based classes but to restrict the item s application to other than steel. Information on that record showed little to no negative handling, stowing or liability considerations for the involved articles. The steel products ranged in density from 0.55 to pcf, with an average of pcf. The densities of the products constructed from other materials fell within this range. That proposal was approved as docketed. The new item (63170) was established, and two new Notes (items and 63172) were also added for clarification purposes. Those changes first appeared in Supplement 1 to NMF 100-AD, effective January 24, 2004, and the provisions have remained unchanged to the present. About Steel Electrical Enclosures Item applies on a variety of steel-fabricated electrical enclosures, including switch boxes and junction boxes. These same products, constructed from all other materials, are named in item Examples of the steel products are pictured 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 National Motor Freight Traffic Association, Inc. Subject 2, Page 3 of 6

4 % of Figures in Interval CCSB DOCKET Transportation Characteristics Density The information of record for steel articles includes 8,676 density observations. The figures range from 0.08 to pcf, with a simple average density of pcf. As the below frequency distribution graph illustrates, the figures are distributed throughout the range. It is also noted that over 84% of the density observations are under 15 pcf. Frequency Distribution 25.00% 24.09% 20.00% 16.04% 16.53% 16.86% 15.00% 10.00% 10.44% 9.61% 5.00% 0.00% 0.02% 0.05% 0.28% 2.47% 3.61% Density Intervals (pcf) The following table compares the densities of steel products under item to those of other materials, including aluminum and plastic, under item Density observations culled from the CCSB s Density Study on item show a density range comparable to that of item While steel electrical enclosures are generally heavier, the closeness of the average densities reveals that the extent of this difference is minimal. Item No. Density Range (pcf) Average Density (pcf) to to The provisions of item 63160, which assign classes based on the CCSB s standard 11- subprovision full density scale, apply on the same commodities as item 63170, but constructed from materials other than steel. When these items are combined, as depicted on page 5, the overall frequency distribution of 14,334 figures is comparable to the above frequency distribution for item Subject 2, Page 4 of National Motor Freight Traffic Association, Inc.

5 % of Figures in Interval CCSB DOCKET Combined Frequency Distribution 25.00% 20.00% 15.00% 20.43% 18.89% 15.15% 18.03% 10.00% 9.18% 8.97% 5.00% 0.00% 0.06% 0.24% 3.91% 2.18% 2.96% Density Intervals (pcf) Handling These products are generally shipped in fiberboard boxes with or without interior packaging and may be shipped on lift truck skids or pallets. No significant handling concerns are identified. Stowability No unusual stowability issues are indicated. Liability There is no indication of any unusual liability considerations. Steel electrical enclosures are not perishable, prone to spontaneous combustion or explosion, unusually susceptible to theft, unusually liable to damage or likely to damage other freight. A limited amount of information on the value of steel electrical enclosures shows a range from $1.18 to $10.19 per pound, with an average of $4.68 per pound. Shipper-provided information also indicates a limited number of claims per year. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. The information of record for steel electrical enclosures, as named in item 63170, shows a density range from 0.08 to pcf, with an average density of pcf. This is inconsistent with the currently assigned class 70, which under CCSB density guidelines, calls for a minimum average density of 15 pcf. Furthermore, as shown on page 4, the information indicates that the density observations of record are widely distributed throughout the range, and over 84% of the figures are lower than 15 pcf. Given the like-nature of the commodities, similar density range and lack of any significant handling, stowing or liability concerns, canceling item with reference to the density-based provisions of item would be consistent with CCSB policy and precedent National Motor Freight Traffic Association, Inc. Subject 2, Page 5 of 6

6 Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 2, Page 6 of National Motor Freight Traffic Association, Inc.