Re: Helicopter Rotor Blades or Rotor Blade Leading Edge Covering CCSB Contact: William F. Mascaro Telephone (703) 838-1834 mascaro@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class AIRCRAFT GROUP: subject to item 11750 12110 Helicopter Rotor Blade Leading Edge Covering, in boxes... 70 12130 Helicopter Rotor Wing Blades, in boxes, crates or containers... 100 12280 Propeller Blades, in boxes or crates... 85 Proposed Classification Provisions Item Description Class AIRCRAFT GROUP: subject to item 11750 12110 Helicopter Rotor Blade Leading Edge Covering, etc.... Cancel; see item 12130 12130 Helicopter Rotor Blades or Rotor Blade Leading Edge Covering, in boxes or crates, see Note, item NEW: Sub 1 Greatest dimension exceeding 288 inches... 300 Sub 2 Greatest dimension exceeding 192 inches but not exceeding 288 inches... 175 Sub 3 Greatest dimension exceeding 96 inches but not exceeding 192 inches... 100 Sub 4 Greatest dimension not exceeding 96 inches... 92.5 NEW NOTE Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment. 12280 Propeller Blades, other than helicopter rotor blades, in boxes or crates... No Change Analysis Research Project 1168 This proposal is based on information developed through Research Project 1168, which was initiated in September of 2012 to investigate the transportation characteristics of helicopter rotor blades and rotor blade leading edge covering. As part of the research, the CCSB mailed commodity questionnaires to 38 potential manufacturers or shippers and 15 trade associations believed to represent those manufacturers or shippers, inviting them to participate in the research. The surveys were mailed in October of 2012, and again in February of 2013 to those that did not respond to the initial mailing. From this sampling, one of the associations forwarded the survey to their members and two associations indicated that they did not represent manufacturers or shippers of the involved articles. Three of the shipper 2013 National Motor Freight Traffic Association, Inc. Subject 11, Page 1 of 7
questionnaires were returned as undeliverable, one company responded that they did not manufacture or ship the involved articles, and four companies provided information, with three of the four responding companies receiving their questionnaires from an association. History of Provisions The provisions of item 12110, naming Helicopter Rotor Blade Leading Edge Covering, were established as a result of action taken on Docket 78, Subject 57 (March-April 1957) and first appeared in Supplement 16 to NMFC A-3, effective August 8, 1957. Information from the record showed a density of 18.17 pcf and a value of $0.90 per pound (in 1957 dollars). There have been no significant changes to the item following its establishment. The provisions of item 12130, naming Helicopter Rotor Wing Blades, were established as a result of action taken on Docket 68, Subject 84 (March-April 1955) and first appeared in Supplement 12 to NMFC A-2, effective August 9, 1955. The documentation for that proposal is no longer available. There have been no significant changes to the item following its establishment. About Helicopter Rotor Blades and Rotor Blade Leading Edge Covering Helicopters are a type of aircraft or rotorcraft capable of lifting off and landing vertically, hovering in place and flying forwards, backwards or laterally. To accomplish this, they utilize a series of rotors which provide both lift and thrust. Most helicopters have a main rotor which is mounted horizontally and a smaller rotor that is mounted vertically on the tail; however, others use two counterrotating horizontal rotors. Attached to the rotors are blades which act as an airfoil (similar to an airplane wing) and provide the force to control the helicopter s movements, e.g. lift and motion. It should be noted that while item 12130 refers to these articles as helicopter rotor wing blades, the reference to wing appears to be archaic as they are commonly referred to as rotor blades. Historical information indicates that, like airplane wings, early helicopter blades were made from different types of wood and fabric. Subsequent blades were made from various types of metals and later composite materials. Regardless of the material from which the blade is made, they are a precision-made piece of equipment, as the failure of a blade could be catastrophic. To protect the leading edge of the rotor blade as it rotates, a replaceable covering may be attached to the blade to help mitigate abrasion and wear. Early edge covers were made from metal or wood; however, composite covers are now also available. Subject 11, Page 2 of 7 2013 National Motor Freight Traffic Association, Inc.
Examples of helicopter rotor blades are shown below. Transportation Characteristics Density In addition to the information developed through the CCSB questionnaire survey, the record also incorporates density observations from other sources, including carrier-supplied data and the CCSB s Density Study 1. Combined, these sources yield 564 density observations ranging from 1.00 to 123.44 pcf, with a simple average density of 10.01 pcf. The table below provides an evaluation of the data based on the reportedly applicable item. Item Density Range (pcf) Average Density (pcf) 12110 2.20-34.30 10.35 12130 1.00-123.44 9.89 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. 2013 National Motor Freight Traffic Association, Inc. Subject 11, Page 3 of 7
A frequency distribution of the overall density range is shown below. Frequency Distribution % of Figures in Interval 30.00% 20.00% 10.00% 0.00% 25.35% 19.68% 15.25% 16.49% 9.40% 0.00% 0.35% 4.08% 6.74% 1.24% 1.42% Density Intervals (pcf) When the data is evaluated based on greatest dimension, where known, the following density ranges and averages are found. It should be noted that ranges overlap, and as the greatest dimension increases, the average density generally decreases. Greatest Dimension Density Range Average Density (pcf) (pcf) Exceeding 288 inches 4.35-10.49 6.50 Exceeding 192 inches but not exceeding 288 inches 3.17-22.86 8.42 Exceeding 96 inches but not exceeding 192 inches 4.29-20.30 12.73 Not exceeding 96 inches 7.68-14.47 11.18 Handling The helicopter rotor blades and rotor blade leading edge coverings of record vary greatly in size, with reported lengths of up to 336 inches (28 feet) and an average length of 212.68 inches (over 17 feet). As the length increases, the handling into and out of the vehicle becomes considerably more difficult, and certain equipment or additional personnel may be necessary to handle the freight. Furthermore, as the length increases, crossdock operations can be significantly affected. Often there is not enough room at carrier facilities to efficiently handle and maneuver excessively long articles, such as the involved helicopter rotor blades and rotor blade leading edge coverings. Subject 11, Page 4 of 7 2013 National Motor Freight Traffic Association, Inc.
When tendered in boxes attached to a lift truck skid or pallet, or in a crate, the freight may be handled more readily with mechanical equipment, since there is clearance for the fork tines to get under and lift them. However, when the length exceeds 96 inches, even freight tendered in packages that provide access for fork tines can be difficult to efficiently handle with mechanical equipment. The level of difficulty increases as the length of the article increases, even if fork extensions are available and used. Stowability These articles are generally tendered in boxes or crates; however, excessively long packages may be difficult to stow with other general freight and will typically require floor loading. Depending on the length of the package, and the other freight that may be in the vehicle, the carrier will have to ensure that the freight will fit in the vehicle. Also, while a flat load-bearing surface may be available for other freight, it can be difficult for the carrier to make efficient use of remaining vehicle space due to the relatively narrow width of the involved packages. Liability A limited amount of information regarding value indicates a range from $19.29 to $571.43 per pound, with a simple average value of $164.73 per pound. Helicopter rotor blades and rotor blade leading edge coverings may be at risk for some damage from handling; however, responding shippers reported few, if any, claims, and there have been no indications from reporting carriers of a claims issue. It should also be noted that, given the potentially catastrophic result of a blade failure, helicopter rotor blades appear to be tendered in packaging that is very capable of withstanding the normal rigors of the LTL transportation environment. Relationship to CCSB Policies and Guidelines CCSB policies state that classifications should reflect a commodity s known transportation characteristics. The information of record includes 564 density observations, which average 10.01 pcf, with a range from 1.00 to 123.44 pcf. Under CCSB guidelines, an average density of 10.01 pcf would generally call for a class 100, absent any negative handling, stowing or liability considerations. However, as discussed in this analysis, helicopter rotor blades and rotor blade leading edge coverings can exhibit significant negative handling and stowing characteristics. Specifically, it was found that greatest dimension has the most considerable effect on the transportability of these products, and as greatest dimension increases the issues increase exponentially. 2013 National Motor Freight Traffic Association, Inc. Subject 11, Page 5 of 7
The following table identifies the resulting average densities, classes based on CCSB density guidelines, and the proposed classes, when the data is evaluated based on greatest dimension (in eight-foot increments). Greatest Dimension Average Density (pcf) Class Based on CCSB Density Guidelines Proposed Class Exceeding 288 inches 6.50 150 300 Exceeding 192 inches but not exceeding 288 inches 8.42 110 175 Exceeding 96 inches but not exceeding 192 inches 12.73 85 100 Not exceeding 96 inches 11.18 92.5 92.5 Based on the information of record, as greatest dimension increases, average density generally decreases and the more difficult the articles are to handle and stow. The proposed classes account for the increasingly less-than-favorable handling and stowing characteristics. Assignment of class 92.5 to helicopter rotor blades or rotor blade leading edge covering having a greatest dimension not exceeding 96 inches is consistent with CCSB guidelines, while the assignment of classes 100, 175 and 300 to those having greatest dimension exceeding 96 inches in respective eight-foot increments reflects the increasingly significant handling and stowing problems associated with those articles. CCSB policies state that commodity descriptions that are a source, or potential source, of interpretation disputes should be amended, and classifications embracing related commodities should be combined. For these reasons, it would be in keeping with CCSB policy to amend item 12280, which applies on aircraft propeller blades, to specifically exclude helicopter rotor blades, thereby clarifying the intent of the item and mitigating the potential for interpretation disputes. Furthermore, it is in keeping with CCSB policy to cancel item 12110, Helicopter Rotor Blade Leading Edge Covering, with reference to item 12130, as proposed, as these items apply on related articles that have comparable transportation characteristics. Additionally, it would also be in keeping with CCSB policies to assign classes in item 12130 based on greatest dimension, with class assignments reflective of the respective less-thanfavorable handling and stowing considerations. Adding an attendant Note to be referenced in item 12130 stating, Greatest dimension refers to the longest straight-line dimension of the handling unit as tendered for shipment, would also be in keeping with CCSB policies respecting clarification. This approach is in keeping with CCSB precedent. As a result of action taken on Docket 2012-2, Subject 4 (May 2012), the provisions of various items applying on brass, bronze or copper pipe, tubing, or pipe or tubing fittings were canceled with reference to a new item (52185) based on greatest dimension as tendered for shipment, with correspondingly higher classes assigned as greatest dimension increases (in eight-foot increments). The proposal was approved as docketed, and the provisions first appeared in Supplement 2 to NMF 100-AL, effective July 21, 2012. Subject 11, Page 6 of 7 2013 National Motor Freight Traffic Association, Inc.
CCSB policies also call on the CCSB to establish and maintain packaging specifications to ensure that freight is adequately protected in the motor carrier environment, and can be handled and stowed in a manner that is reasonably safe and practicable. Presently, item 12130 allows packaging in boxes, crates or containers, although there is no NMFC definition of, or specifications for, the term containers. Removing the reference to containers, while maintaining the packaging requirements of boxes or crates, as proposed, is in keeping with CCSB packaging policy. This proposal, as docketed, is in keeping with CCSB policies and precedent. 2013 National Motor Freight Traffic Association, Inc. Subject 11, Page 7 of 7