Re: Cars, Lift Trucks or Vehicles, electric or internal combustion engine powered, NOI, not designed for general highway use

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1 Re: Cars, Lift Trucks or Vehicles, electric or internal combustion engine powered, NOI, not designed for general highway use CCSB Contact: Daniel E. Horning Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions VEHICLES, MOTOR: subject to item Cars, Lift Trucks or Vehicles, electric or internal combustion engine powered, NOI, not designed for general highway use, exceeding 1,300 pounds net weight Cars, Lift Trucks or Vehicles, electric, NOI, not designed for general highway use and not exceeding 1,300 pounds net weight, in boxes or crates: Sub 1 Without batteries Sub 2 With batteries Cars, Lift Trucks or Vehicles, internal combustion engine powered, NOI, not designed for general highway use and not exceeding 1,300 pounds net weight, in boxes or crates Proposed Classification Provisions VEHICLES, MOTOR: subject to item Cars, Lift Trucks or Vehicles, electric or internal combustion engine powered, NOI, not designed for general highway use, exceeding 1,300 pounds net weight... Cancel; see item Cars, Lift Trucks or Vehicles, electric, NOI, not designed for general highway use and not exceeding 1,300 pounds net weight, etc... Cancel; see item Cars, Lift Trucks or Vehicles, NOI, not designed for general highway Sub 1 use, see Note, item NEW: In boxes or crates, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 8 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 8 but less than Sub 8 12 or greater National Motor Freight Traffic Association, Inc. Subject 8, Page 1 of 5

Proposed Classification Provisions Concluded NEW NOTE Also applies on Tugs or Tuggers, used for pushing or pulling heavy, wheeled equipment or vehicles.

vehicles, not designed for general highway use.

commerce today. Hereinafter, these articles will be referred to as vehicles.

That was a proposal to clarify the provisions for various types of vehicles, including children s cars, motor scooters, all-terrain or multi-terrain vehicles, golf cars and messenger or light

2 Proposed Classification Provisions Concluded NEW NOTE Also applies on Tugs or Tuggers, used for pushing or pulling heavy, wheeled equipment or vehicles. Analysis Research Project 1284 This proposal is based on the information developed through Research Project 1284, involving electric or internal combustion engine powered cars, lift trucks or vehicles, not designed for general highway use. The project was initiated in June 2016 to develop information on the transportation characteristics of these products and to determine if the current provisions are reflective of the goods moving in commerce today. Hereinafter, these articles will be referred to as vehicles. History of Provisions The provisions of items and were established as a result of action taken on Docket 138, Subject 3 (January 1969). That was a proposal to clarify the provisions for various types of vehicles, including children s cars, motor scooters, all-terrain or multi-terrain vehicles, golf cars and messenger or light delivery vehicles. The proposal was approved as modified, and the changes first appeared in Supplement 24 to NMFC A-10, effective August 5, The current provisions of items , and were established as a result of action taken on Docket 903, Subject 12 (May 1990). Information of record indicated a range in density from 1.13 to pcf, with an average of pcf. The changes first appeared in Supplement 2 to NMF 100-Q, effective June 30, The provisions have remained substantially unchanged to the present. About Electric or Internal Combustion Engine Powered Vehicles Items , and cover an array of products that find usage in industry, commercial applications and individual use, including the common forklift, golf car, utility vehicle, warehouse or messenger truck or tractor and the like. They may be powered by either an internal combustion engine or an electric motor. Electric-powered vehicles may be shipped with or without batteries. Walk-behind units, such as tugs or tuggers that allow an individual to move heavy wheeled objects, are also embraced within these provisions. Examples of the involved products are shown below. Subject 8, Page 2 of National Motor Freight Traffic Association, Inc.

Transportation Characteristics The information of record includes 9,977 density observations submitted by shippers and carriers, observed firsthand on CCSB dock surveys and obtained from the

When the data is divided into density groups of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater, as shown in the table, the resultant ranges and averages emerge.

78 Handling When tendered in boxes or crates, the involved vehicles will generally exhibit handling characteristics similar to those of other like-packaged freight.

(In many instances they have been observed as shipped fully assembled with attached handles.

Handling units have been observed with precautionary markings or shipper instructions such as Fragile, Handle With Care, Must Be Kept Upright, This Side Up, Do Not Push and Do Not Crush.

3 Transportation Characteristics The information of record includes 9,977 density observations submitted by shippers and carriers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Study 1. The densities range from 0.92 to pcf, with an average of pcf. When the data is divided into density groups of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater, as shown in the table, the resultant ranges and averages emerge. Group (pcf) Range (pcf) Average (pcf) Less than but less than or greater Handling When tendered in boxes or crates, the involved vehicles will generally exhibit handling characteristics similar to those of other like-packaged freight. However, the involved vehicles may also be tendered loose or secured on lift truck skids or pallets and partially wrapped in plastic film. (In many instances they have been observed as shipped fully assembled with attached handles.) Articles not fully protected and left exposed necessitate more care and attention to mitigate the potential for damage. Handling units have been observed with precautionary markings or shipper instructions such as Fragile, Handle With Care, Must Be Kept Upright, This Side Up, Do Not Push and Do Not Crush. Examples of vehicles as tendered for shipment are shown below. 1 The 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 8, Page 3 of 5

4 Stowability The stowability of these vehicles will vary depending upon the manner in which they are tendered for shipment. In general, they will require floor loading. When tendered in a box or crate, a flat load-bearing surface will typically be present for loading other freight on top, and there will be lateral support for adjacent freight, resulting in a greater ability to readily structure a load and enabling better utilization of available vehicle space. Alternatively, these vehicles may also be shipped loose or secured to lift truck skids or pallets, partially wrapped in plastic film. In such instances, they lack a flat load-bearing surface for top freight and lateral support for adjacent freight. They may also present protrusions, such as handles or other components, that can potentially be damaged or damage adjacent freight. These factors can make it more difficult and time consuming for the carrier to properly structure the load, including necessitating the use of load decks and/or dunnage. Liability Vehicles are not perishable, hazardous in nature or unusually susceptible to theft. As is the case with most general commodities, being fully enclosed within a box or crate will offer greater protection against damage than when tendered loose or secured on lift truck skids or pallets with little or no protective packaging. There were minimal claims reported on movements of these commodities. Value information reveals a range from $1.95 to $11.70 per pound, with an average value of $6.34 per pound. Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. The information of record indicates that the involved vehicles range in density from 0.92 to pcf, with an average 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 characteristics that must also be considered, in accordance with CCSB policies. These have been detailed in the analysis and include such factors as the need for additional care and attention in handling, the inability or additional care and equipment necessary to stack top freight or load adjacent freight, and the inherent risk of damage. However, these issues can be mitigated when the articles are shipped in boxes or crates. In view of the information of record, it would be in keeping with CCSB policy and precedent to establish provisions based on packaging and density, as proposed 2. The table on the following page 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 proposed classes when tendered in boxes or crates according to CCSB density guidelines, and a one-class adjustment to reflect the identified negative handling, stowing and liability considerations when the articles are tendered in packages other than boxes or crates 3. 2 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. 3 The proposed provisions would not authorize loose shipments. Subject 8, Page 4 of National Motor Freight Traffic Association, Inc.

5 Group (pcf) Average (pcf) CCSB Minimum Average Guideline (pcf) Class Based on CCSB Guidelines Class Adjustment Based on Handling, Stowability and Liability Considerations Less than but less than or greater Additionally, a new Note would be established to clarify that the item also applies on tugs or tuggers used to push or pull heavy wheeled equipment or vehicles. Precedent for this approach can be found on Docket , Subject 13 (May 2017), involving solar collectors or panels. was determined to be the primary transportation characteristic when those products were shipped in boxes or one of the authorized numbered packages. When tendered in packages other than boxes or the authorized numbered packages, the products were generally not as well protected and thus presented additional handling, stowability and liability concerns. Accordingly, classes were predicated on packaging and density, assigning respectively higher classes for commodities tendered for shipment in packages other than boxes or the authorized numbered packages. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100- AQ, effective August 5, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent National Motor Freight Traffic Association, Inc. Subject 8, Page 5 of 5

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

Re: Partitions or Partition Doors, steel and wire combined Staff Contact: Daniel E. Horning Telephone (703) 838-1820 horning@nmfta.org Proponent: Commodity Classification Standards Board Present Classification