Re: Doors or Door Sections or Grilles, garage or commercial or industrial building

Transcription

1 Re: Doors or Door Sections or Grilles, garage or commercial or industrial building Staff Contact: Nathan D. Ripke Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Doors or Door Sections, garage or industrial building, overhead, plastic and aluminum, KD flat, with door track packed in same box Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding, rolling or curtain type, NOI, iron or steel, see Note, item 34282, in packages: Sub 1 Greatest dimension 96 inches or more Sub 2 Greatest dimension less than 96 inches NOTE Also applies on accompanying hardware, angles, bars, castings, chain, cable, guides, hoods, pipe, rollers, springs, motors, sprockets, track, hinges, sheaves, brackets, handles, locks, hangers, rails, hooks, pulleys, rods or other fittings when in same package with the doors, door sections, grilles, partitions or shutters, or, when in shipments of 36,000 pounds or more, separate packages Doors, farm, garage, industrial or utility building, overhead, iron or steel, without covering or skin, see Note, item 34311, with or without door track, installation hardware or operating mechanism, in packages NOTE Applies on assembled door framework equipped with hinges and reinforcing trusses but without covering or skin Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding or rolling type, aluminum and iron or steel combined, or aluminum and iron or steel and wood combined, see Note, item Doors or Door Sections, garage or industrial building, overhead or sliding, wooden, with or without hardware applied, in packages, see Note, item National Motor Freight Traffic Association, Inc. Subject 6, Page 1 of 8

2 Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Doors or Door Sections, garage or industrial building, overhead, plastic and aluminum, etc... Cancel; see Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding, rolling or curtain type, NOI, iron or steel, etc... Cancel; see NOTE No Change Doors, farm, garage, industrial or utility building, overhead, iron or steel, without covering or skin, etc... Cancel; see NOTE Cancel; no further application Doors or Door Sections or Grilles, garage or industrial building, overhead, sliding or rolling type, aluminum and iron or steel combined, or aluminum and iron or steel and wood combined, etc... Cancel; see Doors or Door Sections, garage or industrial building, overhead or sliding, wooden, etc... Cancel; see A-NEW Doors or Door Sections or Grilles, garage or commercial or industrial building, overhead, sliding, rolling or curtain type, NOI, in packages, see Notes, items B-NEW and C-NEW B-NEW NOTE Also applies on accompanying hardware and fittings when shipped in the same package. C-NEW NOTE Doors or door sections or grilles tendered for shipment on lift truck skids or pallets must be securely fastened to and must not overhang the edges of the lift truck skid or pallet deck. Exposed surfaces and edges must be completely wrapped with plastic film or corrugated fiberboard or protected by wood or similar material. Subject 6, Page 2 of National Motor Freight Traffic Association, Inc.

3 Analysis Research Project 1163 Research Project 1163 on doors or door sections, garage or commercial or industrial building, overhead, sliding, rolling or curtain type was initiated in May 2012 to review the five items within the Classification that apply on these commodities and to determine their transportation characteristics. Hereinafter, these products will be referred to as doors, door sections or grilles. A total of 156 potential manufacturers or shippers of doors, door sections or grilles, and six associations believed to represent those companies, were sent questionnaires in June and August of Of the companies contacted, one responded that they do not manufacture or ship doors, door sections or grilles, eight questionnaires were returned as undeliverable, and 13 companies provided information; however, not all the information was usable. One association responded that they do not represent the involved companies, while no response was received from the remaining five associations. Additional information was obtained through CCSB dock surveys, carrier-submitted Shipment Information Forms and the CCSB Density Study 1. History of Provisions The current provisions for the involved doors, door sections or grilles are found in five different items, which are based on material consist and/or type. The current provisions of item are the result of action taken on Docket 91, Subject 77 (November 1959). Information on that record revealed densities ranging from 7.31 to 9.27 pcf, and a value per pound of $0.75 (in 1959 dollars). No average density or significant handling, stowability or liability concerns were reported. Approved as modified, those provisions were assigned a class 92.5 and first appeared in Supplement 1 to NMFC A-5, effective September 29, The current provisions of item are the result of action taken on Docket , Subject 10 (August 2005). Information on that record showed densities ranging from to pcf, with an average density of pcf for handling units less than 96 inches in greatest dimension, and a range from 4.28 to pcf, with an average density of pcf for handling units of 96 inches or more in greatest dimension. Value per pound ranged from $1.07 to $10.00, with an average of $2.92 (in 2005 dollars). That proposal was approved as docketed and assigned a class 70 when greatest dimension is less than 96 inches, and a class 85 when greatest dimension is 96 inches or more. The class 85 was based on a one-class increase from the guideline class of 77.5 generally associated with an average density of pcf to account for extra handling and stowability considerations presented by the extended length 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 6, Page 3 of 8

4 of the involved commodities. Those provisions first appeared in Supplement 5 to NMF 100-AE, effective October 29, Item and attendant Note, item were established as a result of action taken on Docket 893, Subject 9 (May 1989) to provide specific provisions reflective of the transportation characteristics of farm, garage, industrial or utility building overhead doors, constructed of iron or steel, without covering or skin. Information on that record revealed densities ranging from 1.65 to 4.00 pcf, with an average density of 2.55 pcf. Those commodities were also reported to have negative handling and stowability characteristics. Approved as docketed, the provisions of item were assigned a class 300 and first appeared, with Note, item 34311, in Supplement 2 to NMF 100-P, effective June 24, The current provisions of item are the result of action taken on Docket 46, Subject 29 (June 1950), which added or Grilles to the commodity description with no class change. Those provisions first appeared in Supplement 14 to NMFC No. 10, effective November 7, Item was established as the result of action taken on Docket 38, Subject 12 (October 1948) to remain competitive with the rails. The item first appeared in Supplement 6 to NMFC No. 10, effective March 14, About Garage or Commercial or Industrial Building Doors, Door Sections or Grilles The involved products are identified as doors, door sections or grilles for garages, or commercial or industrial buildings. These commodities are composed of various materials, including steel, aluminum, wood, plastic or a combination of any of the aforementioned. The doors, door sections or grilles also vary in type, including: overhead, sliding, rolling or curtain functionality. Given their intended use to enclose, secure or protect an open area where vehicles or groups of people may pass through, these commodities can exceed 27 feet in length. Examples of these products are shown below. Subject 6, Page 4 of National Motor Freight Traffic Association, Inc.

5 % of Figures in Interval CCSB DOCKET Transportation Characteristics Density Information of record includes 269 density figures ranging from 1.12 to pcf, with an average of 8.96 pcf. The frequency distribution below shows that the greatest concentration of figures is in the 8 but less than 10 pcf density interval. Frequency Distribution 25% 20% 15% 10% 5% 0% 0% 4% 6% 14% 20% 23% 14% 10% 6% 1% 1% Density Intervals (pcf) As discussed below, the involved doors, door sections or grilles vary greatly in length/size. When the data is evaluated based on greatest dimension 2, as shipped, the following density ranges and averages are found. It should be noted that the ranges overlap, and as the greatest dimension increases, the average density also increases. Density Range (pcf) Average Density (pcf) Greatest dimension exceeding 192 inches Greatest dimension exceeding 96 inches but not exceeding 192 inches Greatest dimension not exceeding 96 inches Handling The doors, door sections or grilles vary greatly in size, with reported lengths up to 27 feet (or 324 inches) or more, and an average length of approximately 14 feet. As the length/size increases, the handling into and out of the vehicle becomes considerably more difficult, and specialized equipment, or additional personnel, may be necessary to safely handle longer units. Furthermore, as the length increases, cross-dock operations can be 2 Item (Rule) 568, Heavy or Bulky Freight Loading or Unloading, uses 8 feet (or 96 inches) in greatest dimension as the threshold measurement at which freight becomes more difficult to load and unload when compared to general boxed freight National Motor Freight Traffic Association, Inc. Subject 6, Page 5 of 8

6 significantly affected. Often there is not enough room at carrier facilities to safely or easily handle and maneuver excessively long doors, door sections or grilles. When a handling unit exceeds 96 inches, even palletized or crated shipments can be difficult to safely handle with mechanical equipment. The level of difficulty increases as the length of the article increases, even if fork extensions are available for use. Ninety-three percent of the observations on this record exceed 96 inches in length. Examples of those shipments are shown below. Stowability Doors, door sections or grilles are tendered in a variety of packages and configurations secured on lift truck skids or pallets, or in crates. The skids or pallets are generally built long enough to support the entire door, door section or grille, but sometimes the freight may overhang the skid or pallet. Handling units not exceeding 96 inches in greatest dimension generally do not pose any unusual or significant stowing problems. However, when handling units of doors, door sections or grilles exceed 96 inches in greatest dimension additional stowing concerns are presented. Furthermore, shipments exceeding 192 inches are even more difficult to stow. Subject 6, Page 6 of National Motor Freight Traffic Association, Inc.

7 While doors, door sections or grilles may be shipped in packages that provide a flat load-bearing surface, many shippers instruct carriers to Do Not Double Stack or Do Not Top Load freight. This limits the carrier s ability to structure a load on and around larger doors, door sections or grilles. Liability Doors, door sections or grilles are not perishable, prone to spontaneous combustion or explosion, or susceptible to theft. The involved commodities do not have the propensity to damage freight with which transported nor are they unusually likely to be damaged in transit. A limited amount of information on value indicates a range from $0.27 to $11.11 per pound, with an average value of $2.71 per pound. Shippers reported six or fewer claims annually, while one carrier reported a claims ratio of 0.53% on shipments currently moving under item and 0.10% for shipments currently moving under item Relationship to CCSB Policies and Guidelines CCSB policies state that classifications should reflect a commodity s known transportation characteristics. The information of record includes 269 density observations, which range from 1.12 to pcf, with an average of 8.96 pcf. Under CCSB guidelines, an average density of 8.96 pcf is generally associated with a class 110, absent any negative handling, stowing or liability considerations. However, as discussed throughout the analysis, doors, door sections or grilles exhibit significant handling and stowability concerns. Specifically, it was found that greatest dimension has the most considerable effect on the transportability of these products, and as the greatest dimension increases the handling and stowing issues increase exponentially. The table below displays the resulting average densities, classes based on CCSB density guidelines and the proposed class when the data is evaluated based on greatest dimension (in eight-foot increments). It should be noted that 93% of the observations of record were found to have a greatest dimension exceeding 96 inches (8 feet). Average Density (pcf) Class Based on CCSB Density Guidelines Proposed Class Greatest dimension exceeding 192 inches Greatest dimension exceeding 96 inches but not exceeding 192 inches Greatest dimension not exceeding 96 inches As shown in the table above, as the greatest dimension increases making the articles more difficult to handle and stow the average density also increases. The proposed class 125 for handling units with a greatest dimension exceeding 192 inches represents a two-class increase from the CCSB guideline class 100 generally associated with an average density of pcf. The proposed class 125 for handling units with a greatest dimension exceeding 96 inches but not exceeding 192 inches represents a one-class increase from the CCSB guideline 2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 7 of 8

8 class 110 generally associated with an average density of 8.44 pcf. When handling units do not exceed 96 inches in greatest dimension, no significant handling, stowing or liability concerns have been identified, making density the primary transportation characteristic. Under CCSB guidelines, an average density of 7.40 pcf is associated with the proposed class 125. CCSB policy regarding clarification, simplification and uniformity calls, in part, 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 current individual classifications for doors, door sections or grilles with reference to a new item applying on overhead, sliding, rolling or curtain-type garage, commercial or industrial doors, door sections or grilles, NOI, at class 125. Combining the classifications into a single item would mitigate, if not solve, any interpretation disputes. Furthermore, two new Notes would be added and referenced by the new item. The first Note would clarify that the provisions also apply on accompanying hardware and fittings when shipped in the same package. The second would provide additional packaging requirements for the involved commodities when tendered on lift truck skids or pallets by specifying the doors, door sections or grilles must be securely fastened to, and must not overhang the edges of, the lift truck skid or pallet, and they must have exposed surfaces and edges completely wrapped with plastic film or corrugated fiberboard or be protected by wood or similar material. This proposal is also in keeping with classification precedent. As a result of action taken on Docket , Subject 4 (May 2012) nine different classifications for brass, bronze or copper pipe, tubing, or pipe or tubing fittings with provisions based on exact material consist and/or type were canceled with reference to a new item (52185). In that proposal, it was found that greatest dimension had the most significant impact on the transportability of those products, and classes were assigned accordingly, with corresponding class adjustments at 96- inch intervals. That proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AL, effective July 21, This proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 6, Page 8 of National Motor Freight Traffic Association, Inc.