Staff Contact: Nathan D. Ripke Telephone (703) Item Description Class

Transcription

1 Re: Insulation or Insulating Material Staff Contact: Nathan D. Ripke Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class INSULATION OR INSULATING MATERIAL GROUP: subject to item Barriers, Shields, Windows or Glass Window Lights or Blocks, radiation shielding, with or without frames, in boxes or crates or on lift truck skids or pallets, 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 but less than Sub but less than Sub or greater NOTE Shipments must have protruding parts adequately protected from possible damage or such parts must be detached and separately boxed Insulation or Insulating Material, viz.: Felt or Felt Paper; Fire Blocking or Sound Attenuation Material, consisting of glass fibers and unexpanded vermiculite, in sheet form, cut, grooved or bent; Insulation or Insulating Material, NOI, see Note, item ; Mineral Wool (Rock, Slag or Glass Wool) or Synthetic Vitreous Fiber; Sleeves or Hollow Shapes, mold riser, exothermic compound; Sound Deadening Material, NOI; In packages, 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 3 but less than Sub 4 6 but less than Sub 5 9 but less than Sub 6 12 but less than Sub 7 15 or greater NOTE When shipments weigh 10,000 pounds or more, provisions also apply on materials necessary for installation not to exceed 33 1 /3 percent of the weight upon which charges are assessed National Motor Freight Traffic Association, Inc. Subject 8, Page 1 of 8

2 Present Classification Provisions Concluded Item Description Class INSULATION OR INSULATING MATERIAL GROUP: subject to item Laminated Wood Fiber, sheeted, NOI: Sub 1 Machine pressed, in bales, boxes or rolls Sub 2 Other than machine pressed, in packages Silencers or Sound Traps, air duct, sheet steel or sheet steel and insulating material combined, in boxes or crates or on skids, 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 Vegetable Fiber Felt, NOI, quilted, in packages THIS SPACE INTENTIONALLY LEFT BLANK Subject 8, Page 2 of National Motor Freight Traffic Association, Inc.

3 Proposed Classification Provisions Item Description Class INSULATION OR INSULATING MATERIAL GROUP: subject to item Barriers, Shields, Windows or Glass Window Lights or Blocks, radiation shielding, etc... Cancel; see item NOTE Cancel; see item NEW Insulation or Insulating Material, viz.: Barriers, Shields, Windows or Glass Window Lights or Blocks, radiation shielding, with or without frames, see Note, item NEW; Felt or Felt Paper; Fire Blocking or Sound Attenuation Material, consisting of glass fibers and unexpanded vermiculite, in sheet form, cut, grooved or bent; Insulation or Insulating Material, NOI; Mineral Wool (Rock, Slag or Glass Wool) or Synthetic Vitreous Fiber; Silencers or Sound Traps, air duct, sheet steel or sheet steel and insulating material combined; Sleeves or Hollow Shapes, mold riser, exothermic compound; Sound Deadening Material, NOI; In packages, 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 Cancel; no further application. NEW NOTE Shipments must have protruding parts adequately protected from possible damage, or such parts must be detached and separately boxed Laminated Wood Fiber, sheeted, NOI, etc... Cancel; believed to be obsolete Silencers or Sound Traps, air duct, etc... Cancel; see item Vegetable Fiber Felt, NOI, quilted, etc... Cancel; believed to be obsolete 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 3 of 8

4 Analysis Research Project 1133 This proposal is based on information developed through Research Project 1133 on insulation or insulating material. During the course of Research Project 1133, 536 potential shippers or manufacturers of insulation or insulating material and 43 associations believed to represent those shippers and manufacturers were contacted in August, and for those that did not respond, again in October of 2011, and invited to participate in the research. From those mailings, 40 companies responded that they do not ship insulation or insulating material, while 33 companies responded stating they ship the involved commodities, with 10 providing usable information. None of the 43 associations provided usable information; however, 11 reported that they do not represent shippers or manufacturers of insulation or insulating material. One association forwarded the questionnaire to its membership. Additional information was developed through carrier-submitted Shipment Information Forms, CCSB dock surveys and the CCSB s Density Study 1. History of Provisions The current full-scale density-based provisions of item were established as a result of action taken on Docket , Subject 3 (November, 2004) and first appeared in Supplement 1 to NMF 100-AE, effective January 22, Information from that record showed that shipments of the involved radiation shielding barriers, shields, windows or glass window lights or blocks ranged in density from 1.89 to pcf, with a simple average density of pcf. Modified density-based provisions for insulating material, NOI, named in item , were established as a result of action taken on Docket No. 79, Subject 26 (June, 1957) and first appeared in Supplement 23 to NMFC No. A-4, effective July 2, Information from that record revealed shipment densities ranging from 3 to 21 pcf, with a simple average of 8 pcf. An additional subprovision, for densities less than 1 pcf, was added to the item as a result of action taken on Docket 761, Subject 72 (January, 1976) to establish more appropriate classes for the commodities having densities of less than 3 pcf. That proposal was approved as modified, and those changes first appeared in Supplement 7 to NMF 100-C, effective August 16, These density provisions have remained substantially unchanged to the present. The full-scale density-based provisions of item were established as a result of action taken on Docket 898, Subject 15 (December, 1989) and first appeared in Supplement 9 to NMF 100-P, effective February 17, That record indicated shipment densities ranging from 2.37 to pcf, with a simple average density of 7.90 pcf and no significant stowing, 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 8, Page 4 of National Motor Freight Traffic Association, Inc.

5 handling or liability concerns. Values per pound on that record ranged from $5.08 to $5.50 (in dollars). The provisions for sheeted laminated wood fiber insulating material, NOI, as named in item , first appeared in Supplement No. 7 to NMFC No. 2, effective July 20, 1937 to remain competitive with the rails and have remained substantially unchanged to the present. The provisions for quilted vegetable fiber felt insulating material, NOI, as named in item , were adopted from the rails in 1936 at a rating equivalent to a class 200. As a result of action taken on Special Docket No. 1 (issued July 20, 1949), the current class 300 was assigned to remain competitive with the rails. That change first appeared in NMFC A-1, effective July 10, 1952, and the provisions have remained substantially unchanged to the present. About Insulation or Insulating Material Insulation and insulating material may be used in a variety of applications to reduce unwanted heat loss or gain, reduce the intensity of sound, resist the flow of electric currents, or shield from radiation exposure. These products are made from a wide variety of materials. Examples of these products tendered for shipment are shown below National Motor Freight Traffic Association, Inc. Subject 8, Page 5 of 8

6 % of Figures in Interval CCSB DOCKET Transportation Characteristics Density The information of record contains 17,420 density observations ranging from 0.06 to pcf, with an average density of 7.97 pcf. The frequency distribution below shows the figures are distributed throughout the density range with a substantial percentage of figures exceeding 20 pcf. Frequency Distribution 30% 25% 26% 23% 20% 15% 10% 5% 1% 7% 14% 8% 5% 5% 6% 2% 3% 0% Density Intervals (pcf) When the data is analyzed based on the applicable item, as reported, the following density ranges and averages are calculated. Item Density Range (pcf) Average Density (pcf) to to to Stowability Insulation or insulating material is shown to be tendered for shipment wrapped in plastic film or in boxes on lift truck skids or pallets, in rolls in plastic bags, in 5-gallon pails, or in boxes not on pallets. Boxed freight may present fewer stowability issues than other packagings, but there is no evidence on this record of unusual or significant problems. Although there is no indication of any unusual or significant stowing considerations, heavy freight should not be loaded on top of insulation or insulating material to avoid damage. Handling A few shipments were labeled, Do Not Puncture or Keep Dry, however, handling should generally be comparable to that of other like-packaged freight. Liability Insulation or insulating material is not perishable nor is it prone to spontaneous combustion or explosion. There is no indication that insulation or insulating material is unusually susceptible to theft, liable to damage or likely to damage other freight with which transported. Information of record from shippers representing up to 70 percent of their respective markets Subject 8, Page 6 of National Motor Freight Traffic Association, Inc.

7 indicates zero to 12 claims annually. This limited information does not indicate an unusual claims issue. A limited amount of information indicates the value per pound ranges from $1.07 to $24.00, with a simple average of $8.64 per pound. One member carrier reported a claims ratio of 0.18 % for shipments moving under item , well below the 1% threshold considered typical for LTL freight operations. Items and There is no indication in the CCSB files or through Internet searches that sheeted laminated wood fiber insulation, as named in item , or quilted vegetable fiber felt insulation, as named in item , are still moving via motor carrier today. Therefore, the provisions of items and may be obsolete. Note, Item Note, item is referenced by item and provides an exception that states, when shipments weigh 10,000 pounds or more, the provisions will also apply on materials necessary for installation not to exceed 33 1 /3 percent of the weight upon which charges are assessed. This exception applies essentially on truckload shipments and may be difficult to accurately apply and enforce. Relationship to CCSB Policies and Guidelines CCSB policies state that the Classification should provide uniformity in provisions addressing the same or similar circumstances published in conjunction with different items. Currently, items , and under the Insulation or Insulating Material Group assign classes based on varying density scales. The table below shows the three density-based items and their density range and current density scale. Item Density Range (pcf) Current Density Scale to CCSB-Standard 11-sub to Modified 7-sub to CCSB-Standard 9-sub The information of record includes 17,420 density observations on insulation or insulating material ranging from 0.06 to pcf, with an average density of 7.97 pcf. CCSB policies 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, especially when there are no unusual or significant stowability, handling or liability concerns. And when the densities are distributed throughout the range and a substantial percentage of the figures exceed 20 pcf, classes based on the CCSB s standard 11-subprovision density scale may be assigned. Such an approach was taken on Docket , Subject 4 (January, 2011), involving item 61700, naming electrical appliances or instruments, NOI. That was a proposal to establish the 11-subprovision density scale within the Electrical Equipment Group for the involved commodities. Information on that record included 30,522 density observations ranging from 1.00 to pcf, with a simple average density of 9.58 pcf, a substantial percentage of figures 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 7 of 8

8 exceeding 20 pcf, and no unusual or significant stowability, handling or liability considerations. Action on that proposal was deferred to Docket (May, 2011) when it was approved as docketed. The amended provisions first appeared in Supplement 2 to NMF 100-AK, effective July 23, Cancelling items and with reference to item , and amending item by establishing classes based on the CCSB s standard 11-subprovision density scale, as proposed, is in keeping with CCSB policy and precedent. Concurrently naming Barriers, Shields, Windows or Glass Window Lights or Blocks, radiation shielding, and Silencers or Sound Traps, air duct, within the viz. listing under item would be in keeping with CCSB clarification policies. Cancelling Note, item and concurrently reestablishing it as a new Note referenced by item would also be in keeping with CCSB policies. CCSB policies also call for the removal of obsolete provisions in the interest of clarification and simplification. Cancelling items and as obsolete, as proposed, is in keeping with CCSB policy. Finally, Note, item applies essentially on truckload shipments and may be difficult to apply correctly and enforce. Cancelling it with no further application, as proposed, is in keeping with CCSB policies. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. Subject 8, Page 8 of National Motor Freight Traffic Association, Inc.