Re: Flooring, Wall Coverings or Wallpaper Staff Contact: Erin N. Topper Telephone (703) 838-8856 topper@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class 70500 FLOOR COVERINGS OR RELATED ARTICLES: 71080 Wall Coverings; or Facings or Flooring; cork; felt paper based, plain or decorated, or linoleum, with or without cellular or expanded plastic or rubber backing of not more than 1 /8 inch thickness; or plastic or rubber, NOI; other than tile or molding, see Note, item 71081, in packages... 70 71081 NOTE For provisions applicable to plastic or rubber tile or molding, see item 182600, 'Tile or Molding, composition, NOI, other than expanded, cellular or foam.' For provisions applicable to cork, felt paper-based or linoleum tile or molding, see item 182635, 'Tile or Molding, cork, felt-base or linoleum.' PAPER: subject to item 150600 151540 Wallpaper, NOI, or Wallpaper Samples or Sample Books, in packages... 70 151560 Wallpaper, blank, unfinished, other than oatmeal or ingrain wallpaper, fiber content consisting of not less than 60 percent ground wood, not including unfinished blank wallpaper that has passed through a further process after its original manufacture, in rolls weighing each 70 pounds or over, or securely fastened on skids or platforms... 55 151570 Wallpaper, blank, unfinished, other than oatmeal or ingrain wallpaper, fiber content consisting of less than 60 percent ground wood, see Note, item 151572, in rolls weighing each 70 pounds or over... 55 151572 NOTE Will also apply on wallpaper samples or sample books not exceeding 2 percent of gross weight of wallpaper and packing. 151580 Wallpaper, blank, unfinished, oatmeal, not colored nor printed, not including paper that has passed through a further process after its original manufacture, in rolls weighing each 200 pounds or over... 55 151600 Wallpaper, oatmeal or ingrain, not printed, see Note, item 151572, in wrapped rolls weighing each 100 pounds or over... 70 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 1 of 8
Proposed Classification Provisions Item Description Class 70500 FLOOR OR WALL COVERINGS AND RELATED ARTICLES GROUP: A-NEW Flooring, Wall Coverings or Wallpaper, NOI, other than tile or molding, see Note, item B-NEW, in boxes or wrapped rolls: Sub 1 Greatest dimension exceeding 96 inches, see Note, item C-NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than 15... 125 Sub 3 15 but less than 22.5... 77.5 Sub 4 22.5 or greater... 65 Sub 5 Greatest dimension not exceeding 96 inches, see Note, item C-NEW, subject to Item 170 and having a density in pounds per cubic foot of: Sub 6 Less than 15... 110 Sub 7 15 but less than 22.5... 70 Sub 8 22.5 or greater... 60 B-NEW NOTE Also applies on Wall Covering or Wallpaper Samples or Sample Books. C-NEW NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. 71080 Wall Coverings; or Facings or Flooring; cork; felt paper based, plain or decorated, or linoleum, with or without cellular or expanded plastic or rubber backing of not more than 1 /8 inch thickness; or plastic or rubber, NOI; other than tile or molding, etc... Cancel; see 71081 NOTE Cancel; no further application. PAPER: subject to item 150600 151540 Wallpaper, NOI, or Wallpaper Samples or Sample Books, etc... Cancel; see 151560 Wallpaper, blank, unfinished, other than oatmeal or ingrain wallpaper, fiber content consisting of not less than 60 percent ground wood, not including unfinished blank wallpaper that has passed through a further process after its original manufacture, etc... Cancel; see 151570 Wallpaper, blank, unfinished, other than oatmeal or ingrain wallpaper, fiber content consisting of less than 60 percent ground wood, etc... Cancel; see 151572 NOTE Cancel; no further application. 151580 Wallpaper, blank, unfinished, oatmeal, not colored nor printed, not including paper that has passed through a further process after its original manufacture, etc... Cancel; see 151600 Wallpaper, oatmeal or ingrain, not printed, etc... Cancel; see Subject 8, Page 2 of 8 2012 National Motor Freight Traffic Association, Inc.
Analysis Research Project 1136 Research Project 1136 on wallpaper or wall coverings was initiated in August of 2011 after a review of items 151540, 151560, 151570, 151580 and 151600. It was found that, except for item 151540, the provisions are very specific as to material consist, stage of manufacture and specific roll weights, which often lead to interpretative difficulties and misclassification of products. Also, during the research project, item 71080 was found to apply on specific types of wall coverings and flooring, as some flooring products may also be used as wall coverings. In conjunction with the project, questionnaires were mailed to 221 potential shippers or manufacturers of wallpaper or wall coverings and 10 associations believed to represent those shippers or manufacturers, in August and October of 2011. From those mailings, usable information was received from three companies; four companies did not provide usable data; one responded that they do not ship their products via less-than-truckload (LTL) motor carrier; and 18 reported that they do not ship or manufacture these products. Of the associations contacted, four responded and indicated that they do not represent these shippers or manufacturers. History of Provisions Provisions for wallpaper, NOI; wallpaper samples or sample books; wallpaper, oatmeal or ingrain, not printed; and unfinished wallpaper were adopted from the rails and first appeared in LTL-1, effective April 1, 1936. The provisions for wallpaper, oatmeal or ingrain, not printed, as currently named in item 151600, have remained substantially unchanged to the present. The provisions for wallpaper, NOI and wallpaper samples or sample books were combined, as currently named in item 151540, at a rating equivalent to the present class 70 in Supplement 1 to NMFC No. 5, effective February 10, 1941. The provisions have remained substantially unchanged to the present. The provisions for the types of wallpaper currently named in items 151560, 151570 and 151580 were established as a result of action taken on Special Docket No. 1 (issued July 20, 1949), first appearing in NMFC A-1, effective July 10, 1952, and remaining substantially unchanged to the present. Provisions for linoleum, cork or felt base carpets or carpeting were adopted from the rails in 1936, at a rating equivalent to class 85. Provisions for rubber matting first appeared in Supplement 1 to LTL-1, effective April 1, 1936. The term synthetic resin composition was added to the rubber matting item in Supplement 4 to NMFC No. 8, effective May 13, 1946. Through a series of proposals over a number of years, the classes for each of the materials were ultimately adjusted to class 70. The most recent was as a result of action taken on Docket 96, Subject 54 (November, 1960), which combined the provisions for plastic and rubber carpets, carpeting, mats or matting, at class 70. The provisions first appeared in Supplement 8 to NMFC A-5, effective May 19, 1961. Other than amendments for clarification and simplification, the provisions (now item 71080) have since remained substantially unchanged. 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 3 of 8
About Flooring, Wall Coverings and Wallpaper The types of flooring, wall coverings and wallpaper involved in this proposal are made of plastic, linoleum, cork, paper and other materials, which are typically sold in rolls. While the research project was initiated on wallpaper or wall coverings, certain products can be used either as a wall covering or as flooring. The photos below are just a few examples of products sold and represented as flooring, wall coverings or wallpaper, as well as wallpaper sample books and a wall covering sample board. It should be noted that flooring and wall tiles and molding are classified elsewhere in the NMFC, and are not involved in this proposal. Subject 8, Page 4 of 8 2012 National Motor Freight Traffic Association, Inc.
Wallpaper and wall coverings are generally tendered on lift truck skids or pallets and may or may not be packaged in fiberboard boxes. As shown in the photos below, rolls may be stacked on lift truck skids or pallets and secured using strapping and/or plastic film. Rolls of flooring can exceed 96 inches long, and may or may not be tendered on lift truck skids or pallets. Transportation Characteristics Density The information of record includes 4,151 density observations submitted by shippers and carriers, obtained during CCSB dock surveys and culled from the CCSB s Density Study 1. The densities range from 2.25 to 97.50 pcf, with an average density of 19.72 pcf. The overall frequency distribution on page 6 shows the densities are distributed throughout the range, but the data can be divided into three density groupings of less than 15 pcf, 15 but less than 22.5 pcf and 22.5 pcf or greater. 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. 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 5 of 8
% of Figures in Interval CCSB DOCKET 2012-3 Frequency Distribution 35% 30% 25% 20% 15% 10% 5% 0% 0% 0% 0% 6% 11% 6% 5% 8% 34% 16% 13% Density Intervals (pcf) When all of the data is evaluated based on the three density groupings, with approximately one-third of the figures in each grouping, the following ranges and averages are calculated. Density Group (pcf) Density Range (pcf) Average Density (pcf) Percentage of Figures Less than 15 2.25 14.99 8.90 37% 15 but less than 22.5 15.00 22.48 18.71 34% 22.5 or greater 22.50 97.50 34.57 29% Handling and Stowability Wall coverings or wallpaper are tendered in boxes or wrapped rolls, generally on lift truck skids or pallets. Flooring tendered in rolls may or may not be palletized for shipment. Most boxed freight provides a flat load-bearing surface for other freight, while rolls may or may not provide a surface for compatible freight. When tendered in rolls not on lift truck skids or pallets, handling may require special equipment (e.g. rug poles) or additional personnel. Rolls may not be as compatible with other freight as boxed shipments and may require floor loading. When the data of record is evaluated based on greatest dimension, where known, it is found that some of the observations exceed 96 inches (8 feet) in greatest dimension 2. (The overall average greatest dimension is approximately 5 feet.) As greatest dimension increases, the handling into and out of the vehicle, and cross-dock operations, become considerably more difficult, and certain equipment, or additional personnel, may be necessary to safely 2 Item (Rule) 568, Heavy or Bulky Freight Loading or Unloading, employs the threshold limit of exceeding 8 feet in greatest dimension as the measurement at which the consignor will perform the loading and the consignee will perform the unloading. Subject 8, Page 6 of 8 2012 National Motor Freight Traffic Association, Inc.
handle the freight. Long rolls may require floor loading and may make it difficult to stow adjacent freight. Rolls that, as tendered, do not provide a flat load-bearing surface further reduce or complicate the carrier s ability to load freight on top and maximize vehicle utilization. Liability Flooring, wall coverings or wallpaper are not likely to damage freight with which stowed and are not unusually susceptible to damage or theft. One carrier reported a claims ratio of 0.23%, which is well within the ratio of 1% or less that is generally considered typical. Only one shipper reported a value per pound, i.e. $7.16. Relationship to CCSB Policies and Guidelines CCSB policies state that provisions of the NMFC that are the source of interpretation disputes should be amended so as to eliminate or avoid those disputes. They also call for combining descriptions embracing related commodities and structuring item descriptions so as to foster clarification and simplification. The involved provisions for flooring, wall coverings and wallpaper are very specific, based on such factors as material consist and stage of manufacture, and have been the source of interpretative difficulties. CCSB policy further calls for classification provisions to reflect a commodity s known transportation characteristics and that unusual or significant stowing, handling or liability characteristics may warrant deviation from the density guidelines. Classification precedent has been to assign a higher class than that usually associated with density when stowability, handling or liability is unusual or significant. When the greatest dimension does not exceed 96 inches, density appears to be the primary transportation characteristic exhibited by the involved commodities. However, when the greatest dimension exceeds 96 inches these commodities may be more difficult to handle and stow. This proposal would establish a new item for flooring, wall coverings or wallpaper, NOI, other than tile or molding, with one set of classes applying when the greatest dimension does not exceed 96 inches, predicated on density with breaks at 15 and 22.5 pcf, as shown in the table below, reflective of the respective average densities for the involved commodities and consistent with CCSB density guidelines. It would assign another set of classes with the identical density groupings, but one class higher than that associated with the density guidelines, when the greatest dimension exceeds 96 inches, as shown in the table 3. Density Group (pcf) Average Density (pcf) Class Based on CCSB Density Guidelines When Greatest Dimension Does Not Exceed 96 CCSB Minimum Average Density Guideline (pcf) One Class Adjustment When Greatest Dimension Exceeds 96 Less than 15 8.90 110 8 125 15 but less than 22.5 18.71 70 15 77.5 22.5 or greater 34.57 60 30 65 3 Both sets of classes would include a reference to Item (Rule) 170, the inadvertence clause. 2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 7 of 8
Concurrently, items 71080, 151540, 151560, 151570, 151580 and 151600 would be canceled with reference to the new item. Two new Notes would be established. The first would state that the provisions also apply on wall covering or wallpaper samples or sample books, and the second would define the term greatest dimension. Notes, items 71081 and 151572 would be canceled as having no further application. This proposal is consistent with classification precedent. An example is Docket 2008-3, Subject 9 (October, 2008), which involved blackboards, chalkboards, corkboards, tackboards, dry erase boards, markerboards or whiteboards, as named in item 23700. Density was shown to be the primary transportation characteristic when the greatest dimension did not exceed 96 inches. However, when the greatest dimension exceeded 96 inches, the involved products were shown to be more difficult to handle and stow. Accordingly, those products not exceeding 96 inches in greatest dimension were assigned density-based classes predicated on the CCSB s density guidelines, while products exceeding 96 inches in greatest dimension were assigned one class higher, respectively. Based on the information of record, this proposal, as docketed, would be consistent with CCSB policies and precedent. Subject 8, Page 8 of 8 2012 National Motor Freight Traffic Association, Inc.