DOCKET 2013-1 JANUARY 2013 - nmfta.org 2013-1/2013_1.pdf · A public meeting on National Motor...

DOCKET 2013-1

JANUARY 2013

A public meeting on National Motor Freight Classification™

provisions will be held on January 29, 2013 at:

The Westin San Diego Hotel

400 West Broadway

San Diego, California 92101

619.239.4500

www.westinsandiego.com

ISSUED: December 13, 2012

©2012 National Motor Freight Traffic Association, Inc.

COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1


Page i

On Tuesday, January 29, 2013, the Commodity Classification Standards Board (CCSB) will

conduct a public meeting to consider proposals for amending the National Motor Freight

Classification™ (NMFC™). The meeting will be held at the Westin San Diego Hotel, 400 West

Broadway, San Diego, California 92101, commencing at 11:00 am.

Section I of this docket provides the CCSB analyses for proposed amendments that will be

considered at the meeting. Each analysis includes the full text of the proposal, the staff

contact and the identity of the proponent.

Section II of this docket provides notice of classification changes made necessary by law, by

order of a regulatory body or for clarification.

The symbol indicates a proposed classification change. The symbol indicates that the

commodities may be subject to federal regulations concerning the shipping of hazardous

materials. The symbol ® indicates a registered trade name or registered trademark. The

symbol ™ indicates a trademark.

Public Docket Files

Supporting data and other relevant information pertaining to each proposal in Section I

herein, including how to contact the proponent, are contained in a Public Docket File. The

public files are available online without charge at www.nmfta.org. They are organized by

docket and subject numbers, and each file is indexed for ease of reference. Interested

persons who do not have Internet access can obtain the public docket file for a particular

proposal from the staff contact, subject to a charge for copying and transmitting the

document(s) requested.

Commodity Classification Standards Board

[email protected] 703.838.1810

Chairman

Joel L. Ringer

Member Member Member

George M. Beck Daniel E. Horning William F. Mascaro

Member Member/Packaging Consultant

Donald A. Newell Erin N. Topper

Counsel

John R. Bagileo


©2012 National Motor Freight Traffic Association, Inc. Page ii

The Commodity Classification Standards Board invites all interested

persons to participate in the classification process.

Anyone having an interest in a proposal listed in this docket is welcome to attend the meeting

and/or submit a statement relating to the transportation characteristics of the product(s)

involved — or relevant to packaging materials or methods in connection with proposed

packaging amendments. Statements should include any underlying studies, supporting data

and other pertinent information.

Written submissions will be included in the respective public docket file. Decisions on

docketed proposals will be based on the information contained in the public docket file.

Any person may become a Party of Record to a docketed proposal by submitting a written

request prior to the meeting. The proponent(s) of a proposal and anyone who attends the

meeting in connection with a proposal or submits a written statement prior to the meeting will

be registered as a party of record to that proposal. Parties of record to a docketed proposal

will receive a disposition of the proposal and will be entitled to seek reconsideration or

arbitration should they disagree with that disposition. (One does not have to be a party of

record to request reconsideration.)

Our address is: Commodity Classification Standards Board, 1001 North Fairfax Street, Suite 600,

Alexandria, Virginia 22314, and our fax number is: 703.683.1094. Written statements may also

be emailed to the staff contact involved. To schedule an appearance at the meeting, or if

you require further information, please get in touch with the staff contact. Anyone requesting

assistance in accordance with the Americans with Disabilities Act will be accommodated.

The CCSB’s policies and procedures as well as other information on the CCSB and the National

Motor Freight Traffic Association are available online at www.nmfta.org.

Amendments to the National Motor Freight Classification™ resulting from the proposals in this

docket will be published in a supplement to the NMFC™, unless reconsideration is granted or

arbitration is sought in accordance with the CCSB’s rules. The supplement is scheduled to be

issued on March 21, 2013, with an effective date of April 20, 2013.

Future CCSB Dockets

Docket 2013-2 Docket 2013-3

Docket Closing Date March 28, 2013 July 18, 2013

Docket Issue Date April 18, 2013 August 8, 2013

CCSB Meeting Date June 3, 2013 September 23, 2013

Dates are as currently scheduled and subject to change. For up-to-date information, go to www.nmfta.org.


INDEX OF SUBJECTS (PROPOSALS)

DESCRIPTION SUBJECT DESCRIPTION SUBJECT

©2012 National Motor Freight Traffic Association, Inc. Page iii

B

Barriers, door or window, detention or

security ................................................... 11

Boxes, cooling, hand portable,

expanded plastic ................................... 8

Burners, boiler, furnace or commercial

or industrial baking oven ....................... 4

C

Cans, waste or refuse, sheet steel ............... 9

Chests, cooling, or Coolers, hand

portable, expanded plastic .................. 8

Containers, liquid or beverage serving,

hand portable, expanded plastic ....... 8

D

Determination of Density – Item (Rule)

110, Sec. 8 .............................................. 13

Displays, video, computer or

multimedia .............................................. 1

Doors or Door Sections or Grilles,

garage or commercial or industrial

building .................................................... 6

Doors, partition, steel and wire

combined .............................................. 10

Doors, screen................................................ 11

E

Electrical Switch Boxes, Conduit Outlet

Boxes or Outlet Box Covers, steel ....... 12

H

Hand Tools, other than power ..................... 3

Holders, waste or refuse, sheet steel or

cast concrete ......................................... 9

I

Ice Buckets, expanded plastic .................... 8

Item (Rule) 110, Sec. 8, Determination

of Density ............................................... 13

K

Kits, expendable aspirating,

administration or transference ............. 2

Kits, inpatient or outpatient care or

treatment ................................................. 2

Kits, maternity ................................................. 2

M

Monitors, video, computer or

multimedia .............................................. 1

O

Oil, Water, Gas Well Group ........................ 15

Outlet Boxes or Outlet Box Covers,

electrical, steel ...................................... 12

P

Partitions or Partition Doors, steel and

wire combined ..................................... 10

R

Receptacles, waste or refuse, sheet

steel or cast concrete ............................ 9

S

Screen Doors or Window Screens ............. 11

Screens, door or window, detention or

security ................................................... 11

Sets, expendable aspirating,

administration or transference ............. 2

Siding, plastic ............................................... 14

Sprayers, boiler, furnace or commercial

or industrial baking oven ....................... 4

Stone Blocks, Pieces or Slabs........................ 7

Switch Boxes, electrical, steel .................... 12

T

Televisions (TVs) .............................................. 1

Tools, hand, other than power .................... 3

V

Vaporizers, boiler, furnace or

commercial or industrial baking

oven ......................................................... 4


INDEX OF SUBJECTS (PROPOSALS)

DESCRIPTION SUBJECT DESCRIPTION SUBJECT

©2012 National Motor Freight Traffic Association, Inc. Page iv

W

Washers (Washing Machines) or

Washer-extractors, laundry, other

than household....................................... 5

Wastebaskets, sheet steel ............................ 9

Water Wheels and Parts ............................. 15

Well Boring or Drilling Machines ................. 15

Window Screens .......................................... 11



CCSB DOCKET 2013-1 SECTION I

SUBJECT 1

©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 1 of 10

Re: Televisions (TVs) or Video, Computer or Multimedia Monitors or Displays

Staff Contact: Nathan D. Ripke Telephone — (703) 838-1869 [email protected]

Proponent: Commodity Classification Standards Board

Present Classification Provisions

Item Description Class

ELECTRICAL EQUIPMENT GROUP: subject to item 60500

63321 Televisions (TVs) or Video or Multimedia Monitors or Displays, NOI, including

LCD or Plasma Televisions (TVs), Monitors or Displays, see Notes, items

63323 and 63324, in boxes or Packages 231, 809, 829, 979, 2320 or

2396, having a screen size measured diagonally of:

Sub 1 40 inches or greater ......................................................................................... 200

Sub 2 Less than 40 inches ........................................................................................... 125

63323 NOTE—Televisions, monitors or displays named in the items making reference to

this Note may be compatible with computers as well as video equipment.

But monitors or displays intended for use exclusively with computers, and

sold expressly as computer monitors or displays, are classified per item

116030, naming 'Machines, Systems or Devices, data processing, or units

that form components of data processing machines, systems or devices.'

63324 NOTE—Not Involved.

63325 Televisions (TVs), projection type, without integral screen, see Note,

item 63323, in boxes ................................................................... Not Involved

THIS SPACE INTENTIONALLY LEFT BLANK


SUBJECT 1


Present Classification Provisions — Concluded


MACHINERY GROUP: subject to item 114000

Business or Office: subject to item 115700

116030* Machines, Systems or Devices, data processing, or Components,

Parts or Peripherals thereof, see Note, item 116033, viz.:

Computers, including Personal Computers, Laptops, Notebooks

or Tablets, or Components, Parts or Peripherals thereof, NOI;

Machines, Systems or Devices, data processing, or Components,

Parts or Peripherals thereof, NOI;

[Other Articles Listed—Not Involved.]

In boxes, crates or Packages 2050, 2253, 2254, 2286 or 2291,

released to a value not exceeding $25.00 per pound, see

Note, item 116031, subject to Items 170 and 171 and

having a density in pounds per cubic foot of:

Sub 1 Less than 1 ....................................................................................... 400

Sub 2 1 but less than 2 .............................................................................. 300

Sub 3 2 but less than 4 .............................................................................. 250

Sub 4 4 but less than 6 .............................................................................. 150

Sub 5 6 but less than 8 .............................................................................. 125

Sub 6 8 but less than 10 ............................................................................ 100

Sub 7 10 but less than 12 ............................................................................ 92.5

Sub 8 12 but less than 15 ............................................................................ 85

Sub 9 15 but less than 22.5 ......................................................................... 70

Sub 10 22.5 but less than 30 ......................................................................... 65

Sub 11 30 or greater ...................................................................................... 60

116031* NOTE—Not involved.

116033* NOTE—Provisions do not apply on cellular or radio telephones, including

smartphones. For cellular or radio telephones, including smartphones, see

item 62820, ‗Radio-telephone Transmitting or Transmitting and Receiving

Sets,‘ for provisions based on released value, and item 62850, ‗Radio-

telephones, cellular (Cellular Telephones),‘ for provisions not based on

released value.

*Published in Supplement 4 to NMF 100-AL, issued on November 1, 2012 with an effective date

of December 1, 2012.


SUBJECT 1


Proposed Classification Provisions



63321 Televisions (TVs) or Video, Computer or Multimedia Monitors or Displays,

NOI, see Note, item 63324, in boxes or Packages 231, 809, 829, 979,

2320 or 2396:

Sub 1 In authorized packages as specified in Note, item NEW, subject to Item

170 and having a density in pounds per cubic foot of:

Sub 2 Less than 4 ................................................................................................... 400

Sub 3 4 but less than 8 .......................................................................................... 175

Sub 4 8 or greater .................................................................................................. 110

Sub 5 In authorized packages other than as specified in Note, item NEW,

subject to Item 170 and having a density in pounds per cubic

foot of:

Sub 6 Less than 4 ................................................................................................... 300

Sub 7 4 but less than 8 .......................................................................................... 150

Sub 8 8 or greater .................................................................................................. 100

NEW NOTE—Applies when the shipping package serves also as the package for

product display or sales purposes and when damage to the package

itself, including cosmetic damage, will result in a claim, and bills of lading

and shipping orders are so notated. The shipping package must also be

marked to indicate that any damage to the package will result in a claim.

63323 NOTE—Cancel; no further application.

63324 NOTE—No Change.

63325 Televisions (TVs), projection type, without integral screen,

in boxes .......................................................................................... No Change


Business or Office: subject to item 115700

116030 Machines, Systems or Devices, data processing, or Components,

Parts or Peripherals thereof, see Note, item 116033, viz.:

Computers, including Personal Computers, Laptops, Notebooks

or Tablets, or Components, Parts or Peripherals thereof, NOI;

Machines, Systems or Devices, data processing, or Components,

Parts or Peripherals thereof, NOI;

[Other Articles Listed—No Change.]

In boxes, crates or Packages 2050, 2253, 2254, 2286 or 2291,

released to a value not exceeding $25.00 per pound, see

Note, item 116031, subject to Items 170 and 171 and


Subs 1-11 No Change.



SUBJECT 1


Proposed Classification Provisions — Concluded


116033 NOTE—Does not apply on:

(1) Cellular or radio telephones, including smartphones. For cellular or

radio telephones, including smartphones, see item 62820, ‗Radio-

telephone Transmitting or Transmitting and Receiving Sets,‘ for

provisions based on released value, and item 62850, ‗Radio-

telephones, cellular (Cellular Telephones),‘ for provisions not based on

released value.

(2) Video, computer or multimedia monitors or displays. For ‗Video,

Computer or Multimedia Monitors or Displays,‘ see item 63321.

Analysis

Research Project 1149

Research Project 1149 was initiated in January of 2012 to review the current

transportation characteristics of televisions (TVs) or video or multimedia monitors or displays.

Hereinafter, these products will be referred to as ―TVs, monitors or displays.‖

A total of 329 potential manufacturers or shippers of TVs, monitors or displays and 27

associations believed to represent those companies, were sent questionnaires in March and

May of 2012. Of the companies contacted, 23 responded that they do not manufacture or

ship TVs, monitors or displays, 21 questionnaires were returned as undeliverable, and seven

companies provided information; however, not all the information was usable. One

association provided usable information, while six association questionnaires were returned as

undeliverable, and five associations stated they do not represent companies of the involved

products. Additional information of record was developed through CCSB dock surveys and

carrier-submitted Shipment Information Forms.

History of Provisions

The provisions of item 63321 were established as a result of action taken on Docket

2005-2, Subject 3 (May 2005) with subprovisions based on screen size. TVs, video or multimedia

monitors or displays having a screen size of 40 inches or greater were assigned class 200 (sub

1), while screen sizes of less than 40 inches were assigned class 125 (sub 2). Information on that

record included direct-view (picture tube or CRT) TVs or monitors, rear projection TVs, LCD TVs

or monitors, but not plasma TVs, monitors or displays, which were, at the time, specifically

named elsewhere in the Classification. Overall density information ranged from 1.64 to 11.88

pcf, with an average of 5.40 pcf. Furthermore, TVs, monitors or displays with screen sizes of 40

inches or greater had an average density of 4.01 pcf and presented negative handling,

stowing and liability characteristics. Screen sizes of less than 40 inches had an average density

of 7.90 pcf with more favorable handling, stowability and liability characteristics. That proposal

was approved as modified, and the provisions first appeared in Supplement 3 to NMF 100-AE,

effective July 23, 2005.


SUBJECT 1


Docket 2007-2, Subject 14 (June 2007) was a proposal by Panasonic Corporation of

North America, Hitachi America, LTD and Phillips Consumer Electronics to amend former item

63322, naming plasma TVs, monitors or displays from a single class 250 to create subprovisions

based on screen size with classes ranging from 200 to 125. Information from that record

revealed plasma TVs ranged in density from 1.78 to 8.06 pcf, with an average of 5.36 pcf.

Handling and stowing concerns were noted. Plasma TVs were to be kept in an upright position

and at times required more than one person for loading and unloading. Some had

precautionary markings, and some required blocking and bracing. The three proponents

reported claims ratios of 10%, 8% and 5% while the average value per pound was $15.72. That

proposal was approved as modified, canceling item 63322 with reference to item 63321,

assigning class 200 to screen sizes 40 inches or greater and class 125 to screen sizes less than 40

inches. This change first appeared in Supplement 3 to NMF 100-AG, effective August 25, 2007.

As a result of action taken on Docket 2007-2, Subject 6 (June 2007) item 63321 was

amended to specifically name LCD TVs, monitors or displays for clarification purposes.

Approved as docketed, the change first appeared in Supplement 3 to NMF 100-AG, effective

August 25, 2007. Item 63321 has remained unchanged to the present.

The current provisions of Note, item 63323 are the result of action taken on Docket 2000-

3, Subject 3 (August 2000). That proposal was to clarify that the provisions for TVs, monitors or

displays apply on products that may be compatible with computers as well as video

equipment; but monitors or displays intended for use exclusively with computers, and sold

expressly as computer monitors or displays, are classified per item 116030, naming ‗Machines,

Systems or Devices, data processing, or units that form components of data processing

machines, systems or devices.‘ Approved as docketed, those changes first appeared in

Supplement 6 to NMF 100-Z, effective October 28, 2000.

About TVs, Monitors or Displays

Information of record encompasses numerous commodities represented as TVs or

video, computer or multimedia monitors or displays. In today‘s market, the involved

commodities predominately consist of a flat panel screen that displays an image through the

use of different lighting technology, including LCD, LED, DLP and Plasma (PDP). These products

are much thinner and lighter than direct-view (picture tube or CRT) products, which are not

included on this record1. Throughout research it was also found that computer monitors or

displays being shipped via LTL motor carrier service today do not function exclusively as

computer monitors. These commodities are equipped with multimedia or video functionality

making them more than just a computer monitor. Pictures of the involved products are shown

on page 6.

1 Old or used direct-view (picture tube or CRT) TVs, monitors or displays, including those destined for

disposal, may still be moving via LTL motor carrier service; however, no information in regard to these

products has been obtained.


SUBJECT 1


Flat Panel Television Flat Panel Multimedia Monitor or Display

Transportation Characteristics

Density—The information of record contains 386 density observations ranging from 0.67 to

28.86 pcf, with an average density of 5.96 pcf. Based on the frequency distribution of the

figures below, the data can be divided into three density groupings of less than 4 pcf, 4 but

less than 8 pcf, and 8 pcf or greater.

When the data is evaluated based on the three density groups, the following ranges

and averages emerge.

Density Group (pcf) Density Range (pcf) Average Density (pcf) Percentage of Figures

Less than 4 0.67 – 3.97 2.57 32%

4 but less than 8 4.02 – 7.99 6.08 42%

8 or greater 8.00 – 28.86 9.80 26%

Handling and Stowability—TVs, monitors and displays require special care and attention in

handling and stowing so as to avoid damage. These products are tendered to the carrier in

boxes that may or may not be secured on lift truck skids or pallets, or in plastic boxes that

0%

5%

10%

15%

20%

25%

1%

7%

23%

19%

23%

18%

8%

1% 0% 0% 0%

% o

f Fig

ure

s in

In

terv

al

Density Intervals (pcf)

Frequency Distribution


SUBJECT 1


provide forklift entry2. Palletized units that do not fully occupy the pallet deck may present

stowing concerns in that they may not provide a regular load-bearing surface for top freight or

lateral support for adjacent freight. In this regard, information of record indicates that TVs,

monitors or displays tendered in this manner exhibit lower densities than that of palletized units

that do fully occupy the pallet deck. Regardless, heavy freight should not be loaded on top of

these products to avoid damage. Pictures of TVs, monitors or displays fully occupying the

pallet deck are shown below.

TVs, monitors or displays tendered to the carrier in boxes not on lift truck skids or pallets

may present negative handling characteristics. Larger, non-palletized TVs, monitors or displays

are generally more difficult to handle; however, they may present a lesser stowing concern

than palletized shipments not fully occupying the pallet deck. The pictures below show two

separate shipments of the same 80-inch TV. In the shipment on the left each TV is strapped to

a pallet and does not fully occupy the respective pallet deck. The shipment on the right is not

palletized, and the TV is strapped to the sidewall of the trailer.

2 One shipper of monitors or displays for tractors ships their products in plastic boxes. This type of

packaging seems to be an exception rather than the industry standard; however, such information is

included on this record.


SUBJECT 1


Also, shippers have noted that special care should be taken when handling and

stowing TVs, monitors or displays. Information of record indicates pictorial markings advising

the carrier to ―Vertical Stack Only,‖ ―Do Not Lay On Side,‖ ―Top Load Only‖ and ―Do Not

Stack‖ shipments. Other instructions to the carrier include ―Shock Watch Handle With Care‖

and ―Do Not Break Down Skids.‖

Liability—TVs, monitors or displays are susceptible to damage due to their inherent fragility.

With regards to claims, one member carrier reported a claims ratio of 0.04%, while another

carrier estimated their claims ratio to be around 5%. A third carrier stated that they do not

track claims by commodity; however, one of their largest customers, who is a frequent shipper

of TVs, has a claims ratio of 4% of revenue, well above the 1% threshold deemed typical for LTL

shipments. An insignificant amount of information with regard to theft was reported on this

record, and value per pound, which provides a measure of potential carrier liability, ranges

from $8.57 to $65.22, with an average of $16.35.

One carrier reported that the most frequent type of claim filed on TVs is for box

damage. Even the slightest damage to a box may result in a refusal and return. In most cases,

a shipper will generally charge between $50 and $100 per box if the TV remains in otherwise

good order. This statement is supported by claims information submitted by a major shipper of

TVs. Seventy-five percent of claims filed by this shipper in a one-year period were for box

damage, with an average of $164.33 per claim.

The picture below provides an example of damage to a box that serves both as the

outer package to protect the TV, monitor or display in transit and the retail package, or shelf-

ready package, for consumer purchase.

TVs, monitors or displays shipped in shelf-

ready boxes are subject to ―special

damages,‖ i.e. the potential liability

increases, as any damage to the box

may result in a claim for the package

only. In most instances, shelf-ready

packaging is easily identifiable, albeit,

many shippers are not advising the

carrier at the time of shipment of the

need for special care and attention in

handling and stowing. Currently, there

are no such requirements in item 63321.

In the picture on the left, the consignee

refused the order due to cosmetic

damage to the package, and the

carrier was charged a repackaging fee.


SUBJECT 1


Relationship to CCSB Policies and Guidelines

CCSB policies state existing classifications should be amended to reflect changes in

transportation characteristics. Research Project 1149 was initiated to determine if the

transportation characteristics of TVs, monitors or displays have changed. The 386 density

observations of record range from 0.67 to 28.86 pcf, with an average density of 5.96 pcf. An

average density of 5.96 pcf is generally associated with class 175, per CCSB density guidelines,

which call for a minimum average density of 5 pcf. However, since the densities are

distributed throughout the range, the density data has been evaluated based on breaks at 4

and 8 pcf. The density averages and associated classes that emerge are shown below.

Density Group

(pcf)

Average Density

(pcf)

Class Based on CCSB

Density Guidelines

CCSB Density

Guideline (pcf)

Less than 4 2.57 300 2

4 but less than 8 6.08 150 6

8 or greater 9.80 100 9

The proposed density breaks tend to address the handling and stowing concerns

observed in TV, monitor or display shipments, as the lower-density shipping units also tend to

exhibit the more significant handling and stowing issues. However, the negative liability

characteristics of these products are not addressed. Liability has long been a concern for

carriers with respect to TVs, monitors or displays and other electronic goods. In this regard, one

of the primary functions of packaging is to protect the freight. If the package is damaged and

the freight is undamaged, then the package has done its job. When a shipping package also

serves as a shelf-ready box for product display or consumer purchase, carriers are required to

take extra care when handling and stowing these products to avoid cosmetic damage to the

package. If there is damage to the box, but not the product itself, the consignee may refuse

the shipment, and the carrier may be charged a repackaging fee. Such measures are not

typically required for general boxed freight.

With respect to commodities that exhibit less-than-favorable handling, stowability or

liability characteristics, classification precedent has been to assign a class one or two classes

higher than what would generally be called for under the CCSB density guidelines. TVs,

monitors or displays shipped in shelf-ready boxes are subject to ―special damages,‖ but many

shippers are not advising the carrier at the time of shipment of the need for special care and

attention in handling and stowing since the current provisions of item 63321 do not require it.

Therefore, it would be in keeping with CCSB policies to amend item 63321 by

establishing classes based on whether or not the TVs, monitors or displays are tendered in shelf-

ready packaging and on density3. Shipments where damage to only the package will result in

a claim would be assigned one class higher than that called for by the average density of

each density group due to the risk of ―special damages‖ associated with shelf-ready boxes.

The table on page 10 details the classes proposed.

3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause.


SUBJECT 1


Density Group

(pcf)

Average Density

(pcf)

Class Based on CCSB

Density Guidelines

One-Class Adjustment

for Liability

Less than 4 2.57 300 400

4 but less than 8 6.08 150 175

8 or greater 9.80 100 110

A new Note would be added to clarify the application of the provisions and to require

the shipper to give notice of the special nature of this freight to the carrier at the time of

shipment on the shipping papers and on the packaging.

Throughout research it was also found that computer monitors or displays being

shipped via LTL motor carrier service today do not function exclusively as computer monitors.

As previously mentioned, these commodities are equipped with multimedia or video

functionality making them more than just a computer monitor. Therefore, it would be in

keeping with CCSB policies to add the term ―Computer‖ to the description of item 63321.

Since the CCSB holds the opinion that the commodities outlined in this proposal are classified

under item 63321, it would be in keeping with CCSB clarification policy to cancel Note, item

63323 with no further application and remove its reference from items 63321 and 63325.

Concurrently, Note, item 116033 would be amended to state that the provisions of item 116030

do not apply on video, computer or multimedia monitors or displays.

Since the majority of TVs, monitors or displays employ LCD or plasma technology in

today‘s market, the reference to ―LCD or Plasma Televisions (TVs), Monitors or Displays‖ within

the description of item 63321 is unnecessary. It would be in keeping with CCSB policy to

remove said reference from item 63321.

Based on the information of record, this proposal, as docketed, is in keeping with CCSB

policy.


SUBJECT 2


Re: Kits, inpatient or outpatient care or treatment; Kits, maternity; or Kits or Sets, expendable

aspirating, administration or transference — Item 56790

Staff Contact: Daniel E. Horning Telephone — (703) 838-1820 [email protected]




DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item 56400

56790 Kits, inpatient or outpatient care or treatment, NOI, see Note, item 56791;

Kits, maternity, see Note, item 56792; or Kits or Sets, expendable

aspirating, administration or transference, with empty plastic

collecting or holding containers, or without containers; in boxes,

subject to Items 170 and 171 and having a density in pounds per

cubic foot of:

Sub 1 Less than 5 ......................................................................................................... 175

Sub 2 5 or greater ........................................................................................................ 100

56791 NOTE—Applies on kits for use in doctors’ offices, hospitals, clinics, nursing homes

or other medical institutions containing a mixture of three or more of the

following: expendable medical instruments, expendable medical

treatment accessories, or other articles for the care or treatment of the

individual; with or without chemicals, drugs or medicines, other than

narcotics.

56792 NOTE—Applies on kits consisting of sanitary pads or pads of similar design and

construction and expendable accessories such as bedding pads, facial

cleansing tissues, paper towels, sanitary belts, plastic shower caps, plastic

gloves, swabs and bottles.



SUBJECT 2




DENTAL, HOSPITAL OR MEDICAL SUPPLY GROUP: subject to item 56400

56790 Kits, inpatient or outpatient care or treatment, NOI, see Note, item 56791;

Kits, maternity, see Note, item 56792; or Kits or Sets, expendable

aspirating, administration or transference, with empty plastic

collecting or holding containers, or without containers; in boxes,

subject to Items 170 and 171 and having a density in pounds per

cubic foot of:

Sub 1 Less than 1 ......................................................................................................... 400

Sub 2 1 but less than 2 ................................................................................................ 300

Sub 3 2 but less than 4 ................................................................................................ 250

Sub 4 4 but less than 6 ................................................................................................ 150

Sub 5 6 but less than 8 ................................................................................................ 125

Sub 6 8 but less than 10 .............................................................................................. 100

Sub 7 10 but less than 12 .............................................................................................. 92.5

Sub 8 12 but less than 15 .............................................................................................. 85

Sub 9 15 but less than 22.5 ........................................................................................... 70

Sub 10 22.5 but less than 30 ........................................................................................... 65

Sub 11 30 or greater ....................................................................................................... 60


56792 NOTE—Applies on kits consisting of bottles, maternity garments, sanitary pads

or related accessories.

Analysis

This proposal is based on information developed through Research Project 1154

involving various kits or sets as named in item 56790. The project was initiated in February 2012

to develop current information on the transportation characteristics of these products and to

determine if the provisions are properly reflective of the nature of goods moving in commerce

today.


During the project, questionnaires were sent to 157 potential manufacturers or shippers

and 26 trade associations related to the medical kits or sets industry. Mailings were sent in

March 2012, and for non-respondents, a second, follow-up letter was sent in May 2012.

Additional contacts were sent letters in June 2012. From those questionnaires, usable

information was received from two companies, while 12 questionnaires were either returned as

undeliverable or the companies were not involved. Responses were received from two of the

associations indicating that they did not represent manufacturers or shippers involved in the

survey.


SUBJECT 2


Additional information was developed through the CCSB Density Study1, CCSB dock

surveys and carrier-submitted reports.


The original provisions for inpatient treatment kits were established as a result of action

taken on Subject 101 of Docket 132 (January 1968). That was a shipper proposal to establish a

new item for expendable treatment kits or trays at class 100. Information of record indicated

an average density of 9.33 pcf and an average value of $1.54 per pound (in 1968 dollars). The

provisions first appeared in Supplement 18 to NMFC A-10, effective May 14, 1969.

Subject 40 of Docket 725 (September 1972) was a proposal to cancel the provisions for

inpatient treatment kits along with the existing entry for hospital patient kits and combine them

along with maternity kits, under a new density-based item2. The proposal was approved as

modified but then subsequently appealed (Appeal 551), upheld on appeal, protested and

suspended (I & S Docket No. M-27910). The ultimate decision in the investigative proceeding

found that the proposed density-based classes were not shown to be just and reasonable,

resulting in no change to the involved provisions.

The matter was revisited under Subject 13 of Docket 756 (September 1975), a proposal

to, among other things, combine and name maternity, aspirating/administration/transference

and treatment kits or sets under one entry, at class 125. Once again, the proposal was

approved as modified, appealed (Appeal 599), protested and suspended, with a second

investigation (I & S Docket No. M-29116). As a compromise, a single density break at 5 pcf was

established along with the institution of the ―bumping‖ privilege, resulting in the current

provisions of what is now item 56790. These amendments appeared in Supplement 9 to NMF

100-D, effective July 30, 1977.

About the Involved Kits or Sets

The attendant Notes governing item 56790 help define for the Classification user the

nature and character of kits or sets embraced by the provisions. In this regard, Note, item

56791, governing inpatient or outpatient care or treatment kits, specifies that such kits are for

use in doctors’ offices, hospitals, etc., and contain a mixture of three or more expendable

components for the care or treatment of an individual. Some examples might include surgical

sets, epidural kits and the like. Similarly, Note, item 56792, governing maternity kits, specifies

that such kits consist of sanitary pads and other expendable accessories, e.g. tissues.

However, it is noted that today’s maternity kits may vary in their make-up or composition;

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. 2 In a related action, Docket 726, Subject 41 (November 1972) proposed the same density scale for

expendable aspirating, administration or transference kits or sets; both subjects were jointly considered

in the same appeal.


SUBJECT 2


different kits may indeed contain different articles or accessories 3. The expendable aspirating,

administration or transference kits or sets named in item 56790 are self-explanatory and

generally apply on kits or sets used to facilitate delivery, drainage or transference. Typical

examples would include medical catheters, as well as gastronomic, infusion or I.V. kits or sets.


Density—The information of record includes 9,998 figures, exhibiting a range in density from

0.17 to 149.65 pcf, for an average density of 8.62 pcf. When grouped according to the

currently applicable subprovisions, the density ranges and averages are as follows:

The frequency distribution of density figures for kits or sets as shown below indicates that

while the overall average density is 8.62 pcf, the greatest concentration of figures is in the 4

but less than 6 pcf interval (41.92%). Further, the density mode and median are 4.88 and 5.65

pcf, respectively. This indicates that the overall average density is not reflective of the density

range, as the range is wide, and moreover, the average corresponds to neither the midpoint

of the range nor the most frequently occurring density in the range.

3 While they generally contain a complement of sanitary napkins or absorbent pads, panties or briefs,

some kits may also include cold packs, digital thermometers and peri bottles. Still others may contain

gloves, towels, antiseptic hand wipes or sterile gauze pads.

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

0.02% 0.38%

12.98%

41.92%

23.00%

7.19% 4.84% 2.96% 2.52% 0.60%

3.58%

% o

f Fig

ure

s in

In

terv

al



Subprovision Density Range (pcf) Density Average (pcf)

Sub 1 - Less than 5 pcf 0.17 to 4.99 4.18

Sub 2 - 5 pcf or greater 5.00 to 149.65 11.65


SUBJECT 2


Handling and Stowability—The involved kits or sets are packaged in inner containers in

fiberboard boxes, which are generally shipped in unitized pallet loads, such as depicted

below, and should not pose any significant handling problems. On selected shipments,

precautionary warnings and instructions are noted, such as ―Do Not Double-Stack‖ and ―Do

Not Break Down Pallet.‖ Care should be taken to load these products with compatible freight

so as to reduce the risk of puncture or contamination – especially in shipments that may

contain sterile components.

Liability—These products are not perishable, prone to spontaneous combustion or explosion,

or highly susceptible to theft, nor are they likely to damage other freight with which shipped.

As mentioned, these products may be liable to damage or contamination; however, shipper-

provided information indicates a limited number of claims per year, with claims ratios below

1%. There is no information available with respect to value per pound.


CCSB policy calls for Classification provisions to reflect a commodity’s known

transportation characteristics. Information of record on the transportation characteristics of

the involved kits or sets reveals a range in density from 0.17 to 149.65 pcf, with an average of

8.62 pcf. The following table relates the information developed to the currently applicable

provisions for both the current class and the class that would generally be applicable for the

known average density per CCSB guidelines.

Subprovision Density

Range (pcf)

Average

Density (pcf) Current Class

Class per

CCSB

Guidelines

Sub 1 - Less than 5 pcf 0.17 to 4.99 4.18 175 200

Sub 2 - 5 pcf or greater 5.00 to 149.65 11.65 100 92.5

As depicted in the table, the provisions for the involved kits or sets are not in keeping

with CCSB guidelines for the currently applicable classes.

CCSB policy further provides that commodities or commodity groups exhibiting a wide

range in density not accurately reflected by a single overall average density may be assigned

density-based classes; especially where there are no unusual or significant stowability,

handling or liability characteristics and where there is no other feasible means of effectively


SUBJECT 2


narrowing the range. And where densities are distributed throughout the range, commodities

or commodity groups may be assigned classes predicated on a full density scale. Further,

when a substantial percentage of the densities involved exceeds 20 pcf, classes based on the

CCSB’s standard 11-subprovision density scale — which ranges from class 400 for densities of

less than 1 pcf to class 60 for densities of 30 pcf or greater — may be assigned.

The involved kits or sets have a density range from 0.17 to 149.65 pcf. The densities are

distributed throughout the range with 4.67% of the figures exceeding 20 pcf. This indicates that

the standard 11-subprovision density scale4 would reflect the densities of the involved kits or

sets as opposed to the current single density break at 5 pcf, and would be consistent with

CCSB policy and precedent.

Since 2000, when the classification policies with respect to full-scale density-based

provisions were changed to include the policy regarding the extended, 11-subprovision

density scale, many items in the NMFC™ have been amended or established to provide that

extended scale. For instance, as a result of action taken on Docket 2012-2, Subject 8 (May

2012), which was a consolidation and updating of insulation or insulating material entries, item

103300 was amended to provide the extended full density scale. The commodities were

shown to have a density range from 0.06 to 99.33 pcf, for an average of 7.97 pcf, with the

densities distributed throughout the full density array and a substantial percentage of densities

exceeding 20 pcf. There were no unusual or significant stowability, handling or liability

characteristics associated with the products. The changes first appeared in Supplement 2 to

NMF 100-AL and became effective July 21, 2012.

CCSB policies also call for replacing outdated terminology and eliminating excess or

unclear wording so as to foster clarification and simplification. In this respect, the provisions

covering maternity kits are not necessarily reflective or inclusive of all kits currently moving in

commerce. The information developed indicates that components may vary and contain

different articles (and not those specified in the attendant Note, item 56792) depending on

the individual kit. Therefore, amending the attendant Note with language that reflects the

varied content of maternity kits would be consistent with CCSB policy.


policy and precedent.

4 The CCSB’s standard 11-subprovision density scale includes reference to Item (Rule) 170, the

inadvertence clause, and Item (Rule) 171, the ―bumping‖ privilege.


SUBJECT 3


Re: Hand Tools, other than power

Staff Contact: William F. Mascaro Telephone — (703) 838-1834 [email protected]




TOOLS, OR PARTS NAMED: subject to item 183550

186630 Tools, NOI, other than plastic, in boxes, drums, or in Packages 1241 or 1273 .. 77.5

186870 Tools, hand, forged, NOI, see Note, item 186903, viz.:

Adzes;

Bars, claw or wrecking, or Crowbars;

Bars, tamping or digging;

Blacksmiths’ Anvil Tools, viz.:

Chisels, counter-sink;

Cutters, cold or hot;

Flatters;

Fullers;

Hammers, set;

Hardies;

Headers;

Punches;

Swages;

Tongs;

Hammers, hand, with 4 pound or heavier head;

Hoes, grub, hazel or accomac;

Mattocks;

Mauls;

Picks;

Railway Track Maintenance Tools, viz.:

Chisels, track;

Forks, rail;

Nippers, tie;

Pullers, spike;

Punches, track tie;

Tongs, tie;

Wrenches, track;

Sledges;

Wedges;

Without handles, or with attached handles, in packages ..................... 60


SUBJECT 3


Present Classification Provisions — Continued


186900 Tools, hand, other than power, other than plastic, see Notes, items 186902

and 186903, viz.:

Awls;

Bevels;

Bits, auger or drill, NOI;

Boxes, miter;

Braces;

Chisels;

Clamps or Screws, bench or hand;

Clippers or Cutters, bolt;

Compressors, piston ring;

Countersinks;

Drills, NOI, including Star Drills;

Expanders;

Extractors, pipe or screw;

Files or Rasps;

Gauges, carpenter;

Gauges, railway track;

Grinders, valve;

Hammers, hand, NOI, with or without handles;

Holders, tool;

Irons, caulking or yarning;

Levels, including carpenters‟ or railway track;

Planes;

Pliers;

Points, bull or moil;

Pullers, gear and wheel terminal, or Parts;

Pullers, nail;

Punches, other than spring type;

Saws, hand, NOI;

Scrapers, carbon;

Scrapers, metal, including Floor and Pipeline Scrapers, Smoothers or

Surfacers, with or without handles, handles may protrude;

Screwdrivers;

Sets, nail;

Sets, saw, or Parts;

Shaves, spoke;

Shears or Snips, tinners‟;

Squares;

Tools, bending or flaring, including Benders, rail;

Tools, body and fender, including Dollies and Spoons;

Tools, brake;

Tools, hand, NOI;

Tools, pipe, including Cutters, Dies, Reamers, Stocks, Threaders or Tongs;


SUBJECT 3




Tools, hand, other than power, other than plastic: subject to item 186900

Tools, tire changing, NOI;

Wrenches, NOI, including Adjustable Wrenches, Pipe Wrenches, or Socket

Wrench Sets;

In packages ........................................................................................................ 70

186902 NOTE—Will also apply on tools packed in tool boxes, cabinets or chests

enclosed in boxes or crates, provided the tools comprise not less than 30

percent of the gross package weight.

186903 NOTE—Provisions do not apply on toy tools. Toy tools are classified under item

84260.



TOOLS, OR PARTS NAMED: subject to item 183550

A-NEW Tools, NOI, hand, other than power, see Notes, items B-NEW and C-NEW, in

boxes, subject to Items 170 and 171 and having a density in pounds

per cubic foot of:

Sub 1 Less than 1 ......................................................................................................... 400

Sub 2 1 but less than 2 ................................................................................................ 300

Sub 3 2 but less than 4 ................................................................................................ 250

Sub 4 4 but less than 6 ................................................................................................ 150

Sub 5 6 but less than 8 ................................................................................................ 125

Sub 6 8 but less than 10 .............................................................................................. 100

Sub 7 10 but less than 12 .............................................................................................. 92.5

Sub 8 12 but less than 15 .............................................................................................. 85

Sub 9 15 but less than 22.5 ........................................................................................... 70

Sub 10 22.5 but less than 30 ........................................................................................... 65

Sub 11 30 or greater ........................................................................................................ 60

B-NEW NOTE—Also applies on tools packed in tool boxes, cabinets or chests enclosed

in boxes or crates.

C-NEW NOTE—Does not apply on toy tools. For applicable provisions, see item 84260,

„Games or Toys, NOI.‟

186630 Tools, NOI, other than hand, other than plastic, in boxes or Packages

1241 or 1273 ................................................................................................... 77.5

186870 Tools, hand, forged, NOI, etc ...................................................................... Cancel; see

item A-NEW

186900 Tools, hand, other than power, other than plastic, etc ........................... Cancel; see

item A-NEW

186902 NOTE—Cancel; see item B-NEW.

186903 NOTE—Cancel; see item C-NEW.


SUBJECT 3


Analysis


This proposal is based on information developed through Research Project 1134

involving hand tools, other than power. The project was initiated in July 2011 in response to

indications of transportation characteristics inconsistent with CCSB guidelines for the currently

applicable classes. As part of the research, 391 potential manufacturers or shippers and six

trade associations were contacted in December 2011, and for those that did not respond,

again in March 2012, inviting them to participate. From this sampling, 48 of the

manufacturer/shipper surveys were returned as undeliverable, 16 companies responded that

they did not manufacture or ship the involved articles, and 23 companies provided at least

some information. Not all of the information was usable, however, and one of the responding

companies requested removal from the mailing list. With respect to the associations, two

responded that they did not represent manufacturers or shippers of the involved articles, and

there was no response from the other four.


The provisions of item 186870 for forged hand tools were established as a result of action

taken on Docket 123, Subject 149 (March-April 1966), and first appeared in Supplement 11 to

NMFC A-9, effective July 20, 1967. The provisions of item 186900 for hand tools, other than

power, were established as a result of action taken on Docket 58, Subject 90 (April 1953), and

first appeared in Supplement 16 to NMFC A-1, effective October 15, 1953. Both items have

remained substantially unchanged since their establishment.

About Hand Tools

Items 186870 and 186900 apply on various types of hand tools that are not power-

operated. Item 186870 applies on certain forged hand tools, while item 186900 embraces

hand tools that are not named elsewhere in the Classification. Both provisions exclude toy

tools and direct the Classification user to item 84260, which names “Games or Toys, NOI.”

Examples of tools embraced within items 186870 and 186900 are shown below and on the

following page.

Forged Hand Tools


SUBJECT 3


Hand Tools


Density—The information of record encompasses 29,622 density observations from a variety of

sources, including shipper- and carrier-supplied data, CCSB dock surveys, and the CCSB‟s

Density Study1. The densities range from 0.32 to 264.00 pcf, with a simple average density of

16.60 pcf. When evaluated by item, hand tools reported to be moving under item 186870

were found to range in density from 0.32 to 149.81 pcf, with an average density of 18.20 pcf,

while hand tools reported to be moving under item 186900 were found to range from 1.04 to

264.00 pcf, with an average density of 16.44 pcf. A frequency distribution of the overall

density range is provided below.




respective freight auditing programs. The data is identified by NMFCTM item, and only verifiable data


used.

0%

5%

10%

15%

20%

25%

30%

0% 0% 0%

6%

12% 12% 12% 14%

28%

7% 9%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 3


As shown in the distribution, the density figures are distributed throughout the range,

and approximately 19% of the figures exceed 20 pcf.

Handling—The information of record indicates that the involved hand tools are generally

tendered for shipment in fiberboard boxes of regular size and shape that may be palletized.

No unusual or significant negative handling considerations have been identified.

Stowability—As with handling, no unusual or significant negative stowability considerations are

noted. The packages will generally provide a flat load-bearing surface for other freight and

should not present any difficulties when structuring a load.

Liability—There is no indication of any unusual or significant liability considerations. None of

the responding manufacturers or shippers provided any information on the value of these

articles; however, there is also no evidence of a claims problem.


CCSB policy regarding clarification, simplification and uniformity calls for combining

descriptions embracing related commodities, eliminating excess or unclear wording,

employing language that is concise and clear as to intent, structuring commodity descriptions

so as to foster clarification and simplification, and listing items under appropriate generic

headings. In keeping with these policies, this proposal would cancel the provisions of items

186870 and 186900 with reference to a new item under the “Tools, or Parts Named” generic

heading for “Tools, NOI, hand, other than power.” Concurrently, Notes, items 186902 and

186903 would be canceled and reestablished in the interest of clarification. In addition, item

186630, applying on “Tools, NOI, other than plastic,” would be amended by the addition of

the restriction, “other than hand,” to avoid a potential interpretation conflict with the

proposed new item, and by removal of the superfluous packaging reference, “in drums.”

CCSB policy also calls for provisions to reflect a commodity‟s known transportation

characteristics. Information of record indicates that hand tools moving under the provisions of

items 186870 and 186900 range in density from 0.32 to 264.00 pcf, with a simple average

density of 16.60 pcf, and no unusual or significant negative handling, stowability or liability

considerations. When evaluated on the basis of the reportedly applicable item, hand tools

moving under the provisions of item 186870 range in density from 0.32 to 149.81 pcf, with an

average density of 18.20 pcf. CCSB guidelines for the currently applicable class 60 call for a

minimum average density of 30 pcf. Hand tools reported to be moving under the provisions of

item 186900 range in density from 1.04 to 264.00 pcf, with an average density of 16.44 pcf.

CCSB guidelines for the currently applicable class 70 call for a minimum average density of 15

pcf.

CCSB policy further provides that commodities exhibiting a wide density range not

accurately reflected by a single overall average density may be assigned density-based

classes; especially where there are no unusual or significant stowability, handling or liability

characteristics and where there is no other feasible means of effectively narrowing the range.

And where densities are distributed throughout the range, commodities may be assigned

classes predicated on a full density scale. In this regard, CCSB policy provides that when a

substantial percentage of the densities involved exceed 20 pcf, the density scale should


SUBJECT 3


incorporate the alternative standard progression of 11 subprovisions that ranges from class 400

for densities of less than 1 pcf to class 60 for densities of 30 pcf or greater.

Canceling the provisions of items 186870 and 186900 with reference to a new item for

hand tools, NOI, other than power, which assigns the CCSB‟s standard 11-subprovision density

scale2, is consistent with the aforementioned policies. It is also consistent with precedent

established by the Surface Transportation Board, which has stated that density is usually the

most important transportation characteristic, and that density-based classes are desirable for

products which pose no significant stowability or handling problems and where there are wide

variations in density. There is also considerable CCSB precedent in support of this proposal. A

recent example may be found in Docket 2012-1, Subject 4 (January 2012), which was a

proposal to cancel various individual items for sinks or lavatories with reference to item 158880

for “Plumbers‟ Goods,” which assigns the standard 11-subprovision density progression, while

concurrently amending item 158880 to name sinks and lavatories.

Based on the information of record, this proposal is in keeping with CCSB policy and

precedent.

2 The CCSB‟s standard 11-subprovision density scale includes reference to Item (Rule) 170, the

inadvertence clause, and Item (Rule) 171, the “bumping” privilege.


THIS PAGE INTENTIONALLY LEFT BLANK


SUBJECT 4


Re: Burners, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven






115520 Burners, NOI, Sprayers or Vaporizers, boiler, furnace or commercial or

industrial baking oven:

Sub 1 Motor operated, in boxes, crates or drums .................................................... 85

Sub 2 Other than motor operated, oil, in boxes, crates or drums .......................... 85

Sub 3 Other than motor operated, gas, in packages ............................................. 85




115520 Burners, NOI, Sprayers or Vaporizers, boiler, furnace or commercial or

industrial baking oven:

Sub 1 In boxes or crates, or in fiberboard containers securely fastened to lift

truck skids or pallets, subject to Item 170 and having a density in

pounds per cubic foot of:

Sub 2 Less than 8 ................................................................................................... 175

Sub 3 8 but less than 12 ........................................................................................ 100

Sub 4 12 or greater .................................................................................................. 70

Sub 5 In packages other than as set forth in sub 1, subject to Item 170 and


Sub 6 Less than 8 ................................................................................................... 200

Sub 7 8 but less than 12 ........................................................................................ 110

Sub 8 12 or greater .................................................................................................. 77.5

Analysis


Research Project 1147 was initiated in December 2011 to investigate the transportation

characteristics of articles moving under the provisions of item 115520, ―Burners, NOI, Sprayers or

Vaporizers, boiler, furnace or commercial or industrial baking oven.‖ The complete description

is found herein under the Present Classification Provisions. During the course of Project 1147,

questionnaires were mailed to 147 potential manufacturers or shippers and nine trade

associations in March of 2012, and again to those that did not respond, in June of 2012,

inviting them to participate in the research. From this sampling, one survey was returned as

undeliverable, three companies responded that they did not ship the involved articles, and


SUBJECT 4


nine companies provided at least some information. One additional company was identified

subsequent to the mailings and they have been added to the Notification List for this proposal.

Regarding the nine trade associations contacted, three responded that they did not represent

shippers of the involved articles. No response was received from the remaining associations.


The basic provisions of item 115520 were adopted from the rails in 1936. With the

exception of packaging changes, the current provisions were established as a result of action

taken on Docket 131, Subject 28 (November 1967). That was a proposal to, among other

things, amend item 115520 to include a reference to burners, sprayers or vaporizers for

commercial or industrial baking ovens. The proposal was approved as modified, and the

changes first appeared in Supplement 13 to NMFC A-10, effective March 12, 1969.

About Burners, Sprayers or Vaporizers

Item 115520 applies on burners, sprayers or vaporizers for boilers, furnaces or

commercial or industrial baking ovens. They are used to control a fuel source to promote

efficient combustion and reduce emissions. Among the most common fuels are natural gas,

propane and oil. While item 115520 references sprayers and vaporizers to further describe

these articles, they are commonly referred to as ―burners.‖ Examples of different types of

burners are shown below.

Boiler Burners

Furnace Burners

Commercial or Industrial Oven Burners


SUBJECT 4



Density—The information of record includes 4,580 density observations submitted by shippers

and carriers, obtained through CCSB dock surveys and culled from the CCSB’s Density Study1.

The observations range from 1.43 to 71.31 pcf, with a simple average density of 12.51 pcf. A

frequency distribution of the overall density range is provided below.

As depicted in the frequency distribution, while the figures are distributed throughout

the range, they are clustered fairly evenly within the three proposed density groups, with 30%

less than 8 pcf, 31% between 8 and 12 pcf, and 39% 12 pcf or greater. The table below

provides an overview of the density observations as they relate to the proposed density

groups.

Proposed Density Group (pcf) Density Range (pcf) Average Density (pcf)

Less than 8 1.43 – 7.98 5.83

8 but less than 12 8.00 – 11.99 10.02

12 or greater 12.00 – 71.31 19.41

A review of the density observations also reveals that there is essentially no difference in

density based on the currently applicable subprovisions, which are predicated on whether or






used.

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

0% 0%

3%

12%

15% 15% 16% 15%

16%

4% 4%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 4


not the burner is motor-operated, and if not motor-operated, the type of fuel burned. This is

illustrated in the table below.

Reportedly Applicable Subprovision Density Range (pcf) Average Density (pcf)

Sub 1 1.43 – 71.31 12.44

Sub 2 2.11 – 65.25 12.73

Sub 3 2.25 – 66.86 12.38

Handling—Information of record indicates that the involved burners are tendered for shipment

in boxes or crates, in fiberboard containers securely fastened to lift truck skids or pallets, or

attached to lift truck skids or pallets. Generally, articles so tendered will not present any

unusual or significant negative handling considerations. It is noted, however, that in an

extremely limited number of instances (nine out of the 4,580 observations of record or 0.20%)

the length of the handling unit may exceed 96 inches due to the size of the burner. In such

rare instances, handling the involved burner may be more difficult.

Stowability—When tendered in a box or crate, or in a fiberboard container securely fastened

to a lift truck skid or pallet, a flat load-bearing surface will 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.

When the involved burners are tendered secured on lift truck skids or pallets, but not in

a box, crate or fiberboard container, they may pose some negative stowability considerations.

Specifically, burners tendered in this manner will generally lack a flat load-bearing surface for

the loading of other freight on top of the article, and they may not provide lateral support for

freight loaded adjacent to them in the vehicle. They may also have protrusions and exposed

surfaces or edges that can limit the type of freight that may be safely stowed around them. In

the LTL environment, this means that carriers will either not be able to load other freight on top

of or adjacent to the unit, or that they will have to employ the use of load decks and/or

dunnage, resulting in an increase in time to properly structure the load.

Liability—The involved articles are not perishable, prone to spontaneous combustion or

explosion, nor susceptible to theft. As is the case with most general commodities, when

tendered for shipment fully enclosed within a box or crate, or in a fiberboard container

secured to a lift truck skid or pallet, they should not be unusually susceptible to damage, nor

likely to damage other freight with which transported.

When tendered on a lift truck skid or pallet without protective packaging, however,

these products may exhibit a greater susceptibility to damage compared to similar units

tendered in a box, crate or fiberboard container. Burners shipped with little or no protective

packaging may have exposed edges or protrusions that can puncture, mar or otherwise

damage adjacent freight. Additionally, shipments loaded in a vehicle are generally

supported to some extent by adjacent freight. When these articles are not in a box, crate or

fiberboard container, they may not provide sufficient lateral support for adjacent freight. This

can result in damage to either the article itself or the adjacent freight.

Information on value is extremely limited, with only one reported figure of $11.36 per

pound, and there is no information available with respect to claims.


SUBJECT 4



CCSB policy calls for provisions to reflect a commodity’s known transportation

characteristics. Information of record shows densities for the involved articles to range from

1.43 to 71.31 pcf, with a simple average density of 12.51 pcf. CCSB policy provides that where

commodities or commodity groups exhibit a wide density range not accurately reflected by a

single, overall average density, they may be assigned density-based classes. However, in this

instance some negative stowability and liability considerations have been identified that must

also be considered, in accordance with CCSB policies. These have been detailed in the

analysis and include such factors as the lack of a flat load-bearing surface for top freight and

the lack of lateral support for adjacent freight when the burner is not tendered fully enclosed

within a box, crate or fiberboard container. In addition, those burners that are not tendered in

boxes, crates or fiberboard containers offer less protection against damage to the burner itself

and to other freight with which it is shipped.

The following table relates the information of record to the proposed density groupings

and CCSB guidelines for the proposed classes for burners tendered in boxes or crates, or in

fiberboard containers securely fastened to lift truck skids or pallets.

Density Group

(pcf)

Density Range

(pcf)

Average Density

(pcf)

Proposed

Class

CCSB Density

Guideline (pcf)

Less than 8 1.43 – 7.98 5.83 175 5

8 but less than 12 8.00 – 11.99 10.02 100 9

12 or greater 12.00 – 71.31 19.41 70 15

With respect to commodities that exhibit significant less-than-favorable stowability or

liability characteristics, classification precedent has been to assign a class higher than what

would generally be called for under the density guidelines. Based on the information of

record, this proposal would establish classes one class higher than that called for under CCSB

density guidelines for the involved articles when tendered in packages other than boxes or

crates, or fiberboard containers securely fastened to lift truck skids or pallets. Such an

approach provides a means of addressing the varying stowing and liability characteristics

associated with these articles, while also providing a method for narrowing the identified wide

density range2.

A similar approach was used with respect to the provisions of item 181700, for iron or

steel tanks. As detailed in the record of Subject 5 of Docket 2010-2 (June 2010), the classes

assigned for each density group reflected a one or two class increase over the class generally

called for under the density guidelines. The proposal was approved as modified, and those

provisions first appeared in Supplement 2 to NMF 100-AJ, effective August 28, 2010.

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 Both sets of classes would include reference to Item (Rule) 170, the inadvertence clause.




SUBJECT 5


Re: Washers (Washing Machines) or Washer-extractors, laundry, other than household

Staff Contact: Donald A. Newell Telephone — (703) 838-1890 [email protected]

Allison L. Austin (703) 838-8864 [email protected]





Laundry: subject to item 124000

Steam, Commercial or Institutional Type, other than household: subject to

item 124225

124350 Washer-extractors, in boxes, crates or Package 2426 ............................ 85

124355 Washers (Washing Machines), power, in boxes, crates or Package

1022 .................................................................................................... 92.5




Laundry: subject to item 124000

Steam, Commercial or Institutional Type, other than household: subject to

item 124225

124350 Washer-extractors, etc. .............................................................. Cancel; see

item 124355

124355 Washers (Washing Machines) or Washer-extractors:

Sub 1 In boxes, crates or Packages 1022 or 2426, subject to Item

170 and having a density in pounds per cubic foot of:

Sub 2 Less than 10 ..................................................................................... 125

Sub 3 10 but less than 15 ............................................................................ 85

Sub 4 15 or greater ...................................................................................... 70

Sub 5 In packages other than boxes, crates or Packages 1022 or 2426,

subject to Item 170 and having a density in pounds per

cubic foot of:

Sub 6 Less than 10 ..................................................................................... 150

Sub 7 10 but less than 15 ............................................................................ 92.5

Sub 8 15 or greater ...................................................................................... 77.5

Analysis


This proposal is based on information developed through Research Project 1110, which

was initiated by the CCSB in November 2009 in response to interpretation inquiries regarding


SUBJECT 5


whether particular products are classified under the provisions of item 124350 as washer-

extractors or item 124355 as washers (washing machines). In opinions, determinations of the

applicable provisions have generally yielded to shipper representation of the products.

During the course of the project, 120 potential manufacturers or shippers of washers or

washer-extractors, and five associations believed to represent those companies, were sent

questionnaires in March, and for those that did not respond, again in May of 2012. Of those

contacted, 11 companies responded that they do not manufacture or ship these articles, one

indicated that they do not ship via less-than-truckload (LTL) motor carrier service, and seven

companies provided at least some information; however, not all the information was usable.

In addition, two associations responded that they do not represent manufacturers or shippers

involved with these commodities. No other associations responded to our request. Additional

information of record was developed through CCSB dock surveys, including a visit to a major

manufacturer of the products, carrier-submitted Shipment Information Forms and the CCSB‘s

Density Study1.


Item 124350, applying on washer-extractors, was established as a result of action taken

on Subject 18 of Docket 101 (November 1961). Information provided by the shipper proponent

showed a range in density from 13.30 to 22.30 pcf. While the densities warranted class 77.5, the

proponent proposed class 85 in light of negative stowability considerations. That proposal was

approved as modified, and the provisions first appeared in Supplement 3 to NMFC A-6,

effective March 22, 1962. They have remained substantially unchanged to the present.

The provisions of item 124355 for washers (washing machines) were adopted from the

rails in 1936. The current class 92.5 was established as a result of action taken on Special

Docket No. 1 (issued July 20, 1949), and first appeared in NMFC A-1, effective July 10, 1952.

The provisions have remained substantially unchanged to the present.

About Washers or Washer-Extractors

The washer-extractor was introduced to provide the additional step of extracting

excess water from the wet fabrics through a spin cycle. Over time, products marketed as

―washers,‖ which previously did not extract water, also became equipped with this function,

generating ambiguity in the NMFC™ provisions. Based on information developed through the

course of research, there appears to be no industry standard delineating the difference

between a washer and washer-extractor. These articles are used in a range of commercial

and institutional settings, including in laundromats, hotels and correctional facilities. As shown

in the examples on the following page, the size, shape and specifications of the washers or

washer-extractors vary, depending upon the needs of the facility.






used.


SUBJECT 5


Shipments of Washers or Washer-Extractors

Washers or washer-extractors may be tendered in crates, in boxes (which may or may

not be palletized), or secured on lift truck skids or pallets. Those tendered on lift truck skids or

pallets may be simply wrapped in plastic film or they may be wrapped in plastic film and have

packing forms such as corner posts, and top and side fiberboard panels.


SUBJECT 5



Density—Overall, the information of record for washers or washer-extractors includes 2,450

density observations. The products range in density from 2.18 to 67.57 pcf, with a simple

average density of 13.16 pcf. The frequency distribution shown below illustrates that the

densities are distributed throughout the range. However, the data can be divided into three

density groupings of less than 10 pcf, 10 but less than 15 pcf, and 15 pcf or greater.

When evaluated on the basis of the three density groupings, the following ranges and

averages are calculated.

Density Group (pcf) Density Range (pcf) Average Density (pcf) Percentage of Figures

in Group

Less than 10 2.18 – 9.98 7.74 38.36%

10 but less than 15 10.00 – 14.99 12.38 27.39%

15 or greater 15.00 – 67.57 19.88 34.25%

Handling—When tendered in crates, or on lift truck skids or pallets, washers or washer-

extractors will generally exhibit handling characteristics similar to those of other like-packaged

freight. These packages may include handling instructions such as ‗Forklift From One Side Only‘

and ‗This End Up.‘

It should be noted that while the majority of shipments appear to be tendered on lift

truck skids or pallets, some boxes are not tendered on lift truck skids or pallets and have

specific pictorial markings instructing the carrier ‗Do Not Forklift.‘ This freight may require the

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

0.00% 0.00% 1.51%

5.22%

10.00%

21.63%

12.33% 15.06%

28.16%

4.33% 1.76%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 5


use of manual handling equipment, but these units are generally lighter and smaller in size,

and there is no evidence to suggest that it presents a significant handling issue.

Stowability—Washers or washer-extractors tendered in boxes or crates

typically do not present any stowability concerns. However, in roughly 50%

of the observations where packaging is known, washers or washer-

extractors are tendered in packages other than boxes or crates. This

includes those on lift truck skids or pallets that are wrapped in plastic film, as

shown in the photograph on the right, or that may be wrapped in plastic

film and have protective packing forms.

When tendered in packages other than boxes or crates, some

negative stowability considerations have been identified. These washers or

washer-extractors may lack a regular load-bearing surface for top freight.

When tendered this way, pictorial markings often indicate ‗Do Not Stack.‘ Also, when placing

the washer or washer-extractor inside the carrier‘s vehicle, such packaging may limit the type

of freight that can be safely stowed adjacent to it. This can result in increased time on the part

of the carrier to properly structure the load, including the use of dunnage, to minimize the

potential for damage.

Liability—Washers or washer-extractors are not perishable, susceptible to theft or given to

spontaneous combustion or explosion. When tendered in boxes or crates, washers or washer-

extractors will generally be afforded more protection against damage than when not so

packaged.

When tendered in packages other than boxes or crates, washers or washer-extractors

may be more susceptible to damage. These packages may provide minimal protection for

the product, creating the potential for damage. Due to the large size of many of these

articles, any protrusions could lead to potential damage to other freight. However, no carriers

have reported a claims issue, and shippers have reported five or fewer claims per year.

Limited value information shows a range from $4.26 to $16.84 per pound, with an average

value of $10.09 per pound.


CCSB policy calls for amending provisions that are a source, or potential source, of

interpretation disputes so as to eliminate or avoid those disputes. The ambiguity between a

washer and washer-extractor has resulted in confusion over the applicable provisions for

commercial washing equipment. Opinion varies within the industry regarding the difference

between a washer and a washer-extractor; thus, there is no definitive differentiation that can

be applied within the NMFC™ regarding these products. As such, in the interest of clarification

and simplification, it would be within CCSB policy to combine these descriptions embracing

related commodities. Under this proposal, the provisions of item 124350 for washer-extractors

would be canceled with reference to item 124355. Concurrently, the description of item

124355 would be amended to include the noun ―Washer-extractors.‖

Information of record shows washers or washer-extractors range in density from 2.18 to

67.57 pcf, with an average density of 13.16 pcf. CCSB policy states that when commodities


SUBJECT 5


exhibit a wide density range, density-based classes may be established. As shown in the table

below, the data can be divided into three density groupings of less than 10 pcf, 10 but less

than 15 pcf, and 15 pcf or greater, with classes reflective of the average density of each

respective grouping.

However, CCSB policies also state that unusual or significant negative handling,

stowability or liability characteristics may warrant deviation from the density guidelines. When

washers or washer-extractors are tendered in boxes or crates, negative handling, stowing or

liability considerations are greatly mitigated. Most boxes or crates provide a flat load-bearing

surface and allow the carrier to safely load freight adjacent to them. Articles tendered in

boxes or crates also typically provide greater protection against damage to the article itself

and to other freight.

Negative stowing and liability concerns have been found when washers or washer-

extractors are tendered for shipment in packages other than boxes or crates. Where

packaging is known, these forms of shipment represent nearly half of all observations. These

packages generally do not provide a flat load-bearing surface, and may require additional

attention, as prescribed by pictorial instructions on the package. They may impede the

carrier‘s ability to safely load adjacent freight and may be more susceptible to damage or

likely to damage other freight during transit.

Based on the identified stowing and liability concerns, classification precedent has

been to assign a class higher than that provided by the CCSB density guidelines. This proposal

would establish classes based on packaging and density2, with a one-class adjustment for

those washers or washer-extractors in packages other than boxes, crates or Packages 1022 or

2426 (which are box-type packages), as shown in the table below.

A similar approach was taken on Subject 1 of Docket 2009-2 (June 2009) involving item

118100, for air compressors. Density was determined to be the primary transportation

characteristic when air compressors were shipped in boxes or crates. When tendered in other

packages, the air compressors were not as well protected as when in boxes or crates and thus

2 Both sets of classes would include reference to Item (Rule) 170, the inadvertence clause.

Density Group

(pcf)

Average Density

(pcf)

Class Based on CCSB

Density Guidelines

CCSB Density

Guideline (pcf)

Less than 10 7.74 125 7

10 but less than 15 12.38 85 12

15 or greater 19.88 70 15

Density Group

(pcf)

Average Density

(pcf)

Class Based on

CCSB Density

Guidelines

One-Class

Adjustment for

Packaging

Less than 10 7.74 125 150

10 but less than 15 12.38 85 92.5

15 or greater 19.88 70 77.5


SUBJECT 5


presented additional stowing and liability concerns. Accordingly, classes were predicated on

packaging and density, assigning one class higher for air compressors tendered for shipment in

packages other than boxes or crates. That proposal was approved as docketed, and the

provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, 2009.






SUBJECT 6


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

Staff Contact: Nathan D. Ripke Telephone — (703) 838-1869 [email protected]




BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item 33570

34270 Doors or Door Sections, garage or industrial building, overhead, plastic

and aluminum, KD flat, with door track packed in same box .............. 92.5

34280 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 ............................................................ 85

Sub 2 Greatest dimension less than 96 inches .......................................................... 70

34282 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.

34310 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 . 300

34311 NOTE—Applies on assembled door framework equipped with hinges and

reinforcing trusses but without covering or skin.

34360 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 34282 .................................................................................... 85

34460 Doors or Door Sections, garage or industrial building, overhead or sliding,

wooden, with or without hardware applied, in packages,

see Note, item 34282 .................................................................................... 70


SUBJECT 6





34270 Doors or Door Sections, garage or industrial building, overhead,

plastic and aluminum, etc ......................................................... Cancel; see

item A-NEW

34280 Doors or Door Sections or Grilles, garage or industrial building,

overhead, sliding, rolling or curtain type, NOI,

iron or steel, etc ........................................................................... Cancel; see

item A-NEW


34310 Doors, farm, garage, industrial or utility building, overhead,

iron or steel, without covering or skin, etc ................................ Cancel; see

item A-NEW


34360 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

item A-NEW

34460 Doors or Door Sections, garage or industrial building, overhead

or sliding, wooden, etc ............................................................... Cancel; see

item A-NEW

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 ................................ 125

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


Analysis


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 2012. 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 Study1.


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 34270 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, 1960.

The current provisions of item 34280 are the result of action taken on Docket 2005-3,

Subject 10 (August 2005). Information on that record showed densities ranging from 11.62 to

27.69 pcf, with an average density of 19.07 pcf for handling units less than 96 inches in greatest

dimension, and a range from 4.28 to 44.61 pcf, with an average density of 14.60 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 14.60 pcf to

account for extra handling and stowability considerations presented by the extended length






used.


SUBJECT 6


of the involved commodities. Those provisions first appeared in Supplement 5 to NMF 100-AE,

effective October 29, 2005.

Item 34310 and attendant Note, item 34311 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 34310 were assigned a class 300 and first appeared, with

Note, item 34311, in Supplement 2 to NMF 100-P, effective June 24, 1989.

The current provisions of item 34360 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, 1950.

Item 34460 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, 1950.

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



Density—Information of record includes 269 density figures ranging from 1.12 to 37.49 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.

As discussed below, the involved doors, door sections or grilles vary greatly in

length/size. When the data is evaluated based on greatest dimension2, 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 1.12 – 26.79 10.23

Greatest dimension exceeding 96 inches but not

exceeding 192 inches 1.48 – 37.49 8.44

Greatest dimension not exceeding 96 inches 1.38 – 13.89 7.40

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.

0%

5%

10%

15%

20%

25%

0%

4% 6%

14%

20% 23%

14%

10%

6%

1% 1%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 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


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

34270 and 0.10% for shipments currently moving under item 34280.


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 37.49 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

10.23

100

125

Greatest dimension exceeding 96

inches but not exceeding 192 inches

8.44

110

125

Greatest dimension not exceeding 96

inches

7.40

125

125

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

10.23 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


SUBJECT 6


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 2012-2, 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, 2012.

This proposal, as docketed, is in keeping with CCSB policies and precedent.


SUBJECT 7


Re: Stone Blocks, Pieces or Slabs

Staff Contact: Erin N. Topper Telephone — (703) 838-8856 [email protected]




GRAVEL OR STONE GROUP: subject to item 90100

90500* Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone,

coquina or cast stone, NOI, see Notes, items 90502, 90503

and 90504:

Sub 1 Mounted diagonally or vertically on lift truck skids, pallets or platforms

or on shipping carriers or racks, see Notes, items 90508

and 90509 .............................................................................................. 150

Sub 2 In boxes or crates, or on lift truck skids, pallets or platforms, other than

as set forth in sub 1, see Notes, items 90506 and 90509 .................... 55

90502* NOTE—Not Involved.




90508* NOTE—Applies on stone blocks, pieces or slabs secured on lift truck skids,

pallets or platforms or shipping carriers or racks in a diagonal or vertical

orientation.


*Published in Supplement 1 to NMF 100-AL, issued on March 15, 2012 with an effective date of

April 14, 2012.



GRAVEL OR STONE GROUP: subject to item 90100

90500 Stone Blocks, Pieces or Slabs, granite, marble, limestone, sandstone,

coquina or cast stone, NOI, see Notes, items 90502, 90503

and 90504:

Sub 1 Mounted diagonally or vertically on lift truck skids, pallets or platforms

or on shipping carriers or racks, see Notes, items 90508

and 90509 .............................................................................................. 150

Sub 2 In boxes or crates, or on lift truck skids, pallets or platforms, other than

as set forth in sub 1, see Notes, items 90506 and 90509:

Sub 3 Exceeding 96 inches in length .................................................................... 77.5

Sub 4 Not exceeding 96 inches in length ............................................................ 60


SUBJECT 7








90508 NOTE—Applies on stone blocks, pieces or slabs, boxed or other than boxed,

secured and oriented diagonally or vertically on lift truck skids, pallets or

platforms or shipping carriers or racks.


Analysis

Research Project 1122 and Background of Proposal

This proposal is based on information developed through the continuation of Research

Project 1122. The project was initiated in November of 2010 based on reports that shipments

of stone blocks, pieces or slabs, as named in item 90500, specifically when tendered on A-

frame shipping racks, exhibit transportation characteristics inconsistent with the then-assigned

class 50.

Subject 2 of Docket 2012-1 (January, 2012) was a proposal to amend item 90500 by

assigning a class 150 on stone blocks, pieces or slabs tendered mounted in a diagonal or

vertical orientation on lift truck skids, pallets or platforms or on shipping carriers or racks, and a

class 55 on those tendered in boxes or crates, or on lift truck skids, pallets or platforms, not

mounted in a diagonal or vertical orientation. Based on the information of record, that

proposal was approved as docketed. The amended provisions first appeared in Supplement 1

to NMF 100-AL, effective April 14, 2012. During the January, 2012 CCSB meeting where that

proposal was considered, interested persons in attendance noted the extreme length of many

of the handling units involved, and expressed concern that that factor might not have been

fully taken into account. Therefore, the research project was kept active.

Subsequent analysis of the previous docket record shows that 97% of the diagonally or

vertically mounted stone blocks, pieces or slabs exceed 96 inches in length. As detailed in the

analysis of, and addendum to, Docket 2012-1, Subject 2, the assigned class 150 took into

account the respective transportation characteristics, including the loaded density of these

stone blocks, pieces or slabs. On the other hand, on the previous record only 26% of stone

blocks, pieces or slabs not mounted diagonally or vertically for shipment exceeded 96 inches

in length. Moreover, a review of that record reveals that the assigned class 55 was based on a

one-class increase from the CCSB guidelines, due to negative handling, stowing and liability

considerations, but it did not take into account the length of the handling units. This proposal

evaluates the data obtained in connection with the project to date with regard to the

products that are not mounted diagonally or vertically for shipment, as named in sub 2 of item

90500.


SUBJECT 7


Shipments of Stone Blocks, Pieces or Slabs

The stone blocks, pieces or slabs named in sub 2 of item 90500 may be shipped in boxes

or crates, but are often shipped on lift truck skids, pallets or platforms (hereinafter referred to as

―pallets‖). The shipments may contain single or multiple blocks, pieces or slabs, which when

not tendered boxed or crated may or may not be covered with fiberboard, plastic film or

wood. The pallets are generally built long enough to support the entire block(s), piece(s) or

slab(s).

Examples of shipments that are classified under sub 2 of the current provisions are

shown below.


SUBJECT 7



Density—The information of record includes 123 shipment observations of stone blocks, pieces

or slabs not mounted diagonally or vertically for shipment, as named in sub 2 of item 90500,

which were submitted by shippers and carriers, and obtained during CCSB dock surveys. The

densities range from 3.37 to 120.17 pcf, with an average density of 34.10 pcf1. Forty-eight

percent of the figures are 30 pcf or greater as shown in the frequency distribution below.

When the data is evaluated based on the handling unit’s length, the following density

ranges and averages emerge.

Handling Unit Length Density Range

(pcf)

Average Density

(pcf)

Percentage of

Figures

Exceeding 96 inches 5.14 – 98.71 23.05 43%

Not exceeding 96 inches 3.37 – 120.17 42.62 57%

Handling—Extra care and attention is necessary when handling stone blocks, pieces or slabs,

as evidenced by the precautionary markings, ―Fragile,‖ ―Handle with Care,‖ ―Must Use Fork

Extensions,‖ and ―This End Up.‖ When the length exceeds 96 inches, additional equipment,

such as fork extensions, or additional personnel may be necessary to safely handle the freight.

1 The average density on the record of Docket 2012-1, Subject 2 was 49.99 pcf.

0%

10%

20%

30%

40%

50%

0% 0% 1% 3% 4%

7% 5% 6%

17%

10%

48%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 7


Stowability—Stone blocks, pieces or slabs will likely require floor loading due to the weight.

When not mounted diagonally or vertically for shipment, the freight will generally provide a

regular load-bearing surface, although some handling units are marked with shippers’

instructions, ―Do Not Double Stack.‖ The information of record shows that while the majority of

these handling units do not exceed 96 inches in length, many do, as previously noted.

Handling units that exceed 96 inches in length present additional stowing considerations.

Liability—Stone blocks, pieces or slabs are susceptible to damage, particularly when not in

boxes or crates or not adequately protected by packaging materials, such as fiberboard or

wood. Many shipments are labeled with instructions to the consignee to inspect the freight for

damage before accepting the shipment or are labeled ―High Claim Value.‖ Four shippers

report two claims or fewer per year. Although one carrier no longer handles this freight due to

high claims ratios, other carriers did not indicate a significant claims problem. The value per

pound of the units in question ranges from $0.04 to $5.71, with an average of $1.03 per pound.

Note, Item 90508

Based on the transportation characteristics evaluated in Docket 2012-1, Subject 2,

Note, item 90508 was established. The Note defines the term ―Mounted diagonally or

vertically on lift truck skids, pallets or platforms or on shipping carriers or racks.‖ During the time

this Note has been in effect, some interpretation inquiries have been received by the CCSB as

to the application of these provisions. Clarifying the verbiage of the Note may assist in

mitigating such interpretation requests in the future.


During the consideration of Subject 2 of Docket 2012-1, it was questioned whether or

not the excessive length of certain handling units of stone blocks, pieces or slabs had been

fully taken into account. As discussed in the Analysis herein, the length of handling units of

these products when not mounted diagonally or vertically for shipment, as named in sub 2 of

item 90500, was not specifically considered in that proposal.

The information of record includes 123 shipment observations of stone blocks, pieces or

slabs not mounted diagonally or vertically for shipment. The range in density is from 3.37 to

120.17 pcf, with an average density of 34.10 pcf. An average density of 34.10 pcf is generally

associated with a class 60, which under CCSB guidelines calls for a minimum average density

of 30 pcf.

Stone blocks, pieces or slabs are inherently liable to damage. When tendered in boxes

or crates or adequately protected by packaging materials, the risk of damage may be

mitigated; nevertheless, extra care and attention is necessary when handling and stowing

these products, as evidenced by such precautionary markings or instructions as ―Fragile,‖

―Handle with Care,‖ ―Must Use Fork Extensions,‖ ―This End Up‖ and ―Do Not Double Stack.‖ As

discussed in the Analysis section, handling units of stone blocks, pieces or slabs that exceed 96

inches in length, result in additional, negative handling and stowing characteristics.


SUBJECT 7


CCSB policies state that classification provisions should reflect a commodity’s

transportation characteristics. Based on the information of record, it would be in keeping with

CCSB policies to amend item 90500 to provide classes based on length for stone blocks,

pieces or slabs not mounted diagonally or vertically for shipment, as named in sub 2 of the

item. In view of their respective transportation characteristics, handling units not exceeding 96

inches in length would be assigned a class 60 — one class higher than that called for under

CCSB guidelines — and handling units exceeding 96 inches in length would be assigned a

class 77.5 — two classes higher than that called for under CCSB guidelines. The associated

average densities and classes are shown in the table below.

Handling Unit

Length

Average

Density

(pcf)

CCSB Minimum

Average

Density

Guideline (pcf)

Class Based

on CCSB

Guidelines

Class Adjustment Based on

Handling, Stowability and

Liability Considerations

Exceeding 96

inches 23.05 22.5 65 77.5

Not exceeding

96 inches 42.62 35 55 60

Note, item 90508 would be amended to provide additional clarification for stone

blocks, pieces or slabs mounted diagonally or vertically on lift truck skids, pallets or platforms or

on shipping carriers or racks.

This proposal, as docketed, is in keeping with CCSB policies and precedent.


SUBJECT 8


Re: Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets; Containers, liquid or beverage

serving; or Coolers or Cooling Boxes, beverage, containing refrigerant; hand portable,

expanded plastic

Staff Contact: George M. Beck Telephone — (703) 838-1813 [email protected]

Proponent: Lifoam Industries, LLC, Hunt Valley, Maryland



PLASTIC OR RUBBER ARTICLES OR MATERIALS, EXPANDED, GROUP: subject to

item 157300

157320 Articles, Forms or Materials, viz.:

[Articles Listed — Not Involved.]

In bags, boxes or drums, see Note, item 157342, subject to Items

170 and 171 and having a density in pounds per cubic foot of:

Sub 1 Less than 1 ............................................................................................ 400

Sub 2 1 but less than 2 ................................................................................... 300

Sub 3 2 but less than 4 ................................................................................... 250

Sub 4 4 but less than 6 ................................................................................... 150

Sub 5 6 but less than 8 ................................................................................... 125

Sub 6 8 but less than 10 ................................................................................. 100

Sub 7 10 but less than 12 .................................................................................. 92.5

Sub 8 12 but less than 15 ................................................................................. 85

Sub 9 15 or greater ............................................................................................ 70




157455 Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets; Containers, liquid

or beverage serving; hand portable, with or without components or

affixed accessories of other materials, in boxes:

Sub 1 With integral refrigerant gel filled lid ............................................................. 250

Sub 2 Other than with integral refrigerant gel filled lid ......................................... 400

157460 Coolers or Cooling Boxes, beverage, hand portable, containing

refrigerant, with or without cloth carrying bag, in boxes, having

a density in pounds per cubic foot of 5 or greater, see

Note, item 157461 ...................................................................................... 150

157461 NOTE—Density must be shown by the shipper on shipping orders and bills of

lading at time of shipment. If density is not shown and shipment is

inadvertently accepted, charges will initially be assessed under the

provisions for 'Expanded Plastic Boxes, cooling, NOI,' per item 157455.

Upon satisfactory proof of actual density, freight charges will be adjusted

accordingly.


SUBJECT 8




PLASTIC OR RUBBER ARTICLES OR MATERIALS, EXPANDED, GROUP: subject to

item 157300

157320 Articles, Forms or Materials, viz.:

Boxes or Chests, cooling, NOI, or Coolers, NOI, hand portable;

Containers, liquid or beverage serving, hand portable;

Ice Buckets;

[Other Articles Listed — No Change.]

In bags, boxes or drums, see Note, item 157342, subject to Items

170 and 171 and having a density in pounds per cubic foot of:

Sub 1 Less than 1 ............................................................................................ 400

Sub 2 1 but less than 2 ................................................................................... 300

Sub 3 2 but less than 4 ................................................................................... 250

Sub 4 4 but less than 6 ................................................................................... 150

Sub 5 6 but less than 8 ................................................................................... 125

Sub 6 8 but less than 10 ................................................................................. 100

Sub 7 10 but less than 12 .................................................................................. 92.5

Sub 8 12 but less than 15 ................................................................................. 85

Sub 9 15 or greater ............................................................................................ 70




157455 Boxes or Chests, NOI, cooling; Coolers, NOI; Ice Buckets;

Containers, etc ............................................................................ Cancel; see

item 157320

157460 Coolers or Cooling Boxes, beverage, hand portable, etc ............... Cancel; see

item 157320


Analysis

This proposal was docketed to address interpretation disputes between the proponent

and its various carriers on shipments of the proponent’s coolers; in particular, those coolers

represented as Koolit Bags. According to the proponent, the carriers are applying four

different classification provisions. The CCSB has issued opinions that the applicable

classification provisions are in item 157455, as shown in the present provisions herein.


The provisions of item 157455 were established as a result of action taken on Docket

703, Subject 50 (May 1970), and first appeared, with a class 400, in Supplement 27 to NMFC A-

11, effective May 31, 1971. The coolers or cooling chests on that record produced a range in

density from 0.37 to 2.18 pcf, with an average density of 1.11 pcf. The ice buckets on that

record ranged from 0.81 to 1.31 pcf (two figures), with an average of 1.05 pcf.


SUBJECT 8


As a result of action taken on Docket 734, Subject 27 (July 1973), item 157455 was

amended to add a subprovision for products with integral refrigerant gel-filled lids at class 250,

and the class 400 was retained for those products without integral refrigerant gel-filled lids. This

change first appeared in Supplement 4 to NMF 100-A, effective June 21, 1974.

Item 157460 was established as a result of action taken on Docket 742, Subject 47

(March 1974), and first appeared in Supplement 1 to NMF 100-B, effective April 1, 1975. The

involved coolers had densities from 5.70 to 6.60 pcf.

About Expanded Plastic Coolers, Ice Buckets, etc.

Expanded plastic hand portable cooling boxes or chests, coolers, ice buckets and

liquid or beverage serving containers were originally an inexpensive alternative to such

products made of other materials. Their light weight made them easy to carry. They are

generally used to keep beverages and other items cold.

Examples of the coolers and ice buckets embraced by item 157455 are shown below:

The following is a picture of the cooler with refrigerant core that established item

157460:


SUBJECT 8


The proponent’s products include the following expanded plastic coolers:

The proponent’s products are manufactured from expanded plastic with or without

components of other materials. As previously mentioned, the proponent’s Koolit Bags have

been the subject of interpretation questions. They are constructed with a vinyl exterior, a thin

layer of expanded plastic, which is the primary construction material and insulating medium,

and a non-expanded plastic handle. These coolers are collapsed and folded in inner

containers when shipped, as shown below.


SUBJECT 8



Density—The data furnished by the proponent yields two density figures: 1.07 and 3.93 pcf. In

addition, the CCSB Density Study1 contains 126 density figures for products reported to be

moving under items 157455 and 157460, ranging from 0.33 to 10.90 pcf. The average density of

all figures is 3.62 pcf. A frequency distribution is shown below.

Handling—The information of record indicates that the involved articles are generally

tendered for shipment in fiberboard boxes of regular size and shape and palletized.

No unusual or significant negative handling considerations have been identified.

Stowability—The information of record does not suggest that stowability of these articles

presents any significant negative considerations. However, as with other lightweight and foam

plastic products, consideration should be given as to where the articles are stowed to avoid

crushing. In this regard, the proponent states that these articles are “actually used in many

cases as top freight.”

Liability—The proponent’s information indicates that the average value per pound for these

products is between $5.00 and $5.35. Proponent also states that claims for these products are

less than 0.05% a year.






used.

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

7%

14%

43%

27%

5% 4% 1% 0% 0% 0% 0% %

of

Fig

ure

s in

In

terv

al




SUBJECT 8



This proposal would cancel items 157455 and 157460 and name the involved

commodities in item 157320, which provides classes based on the CCSB’s standard

nine-subprovision density scale that ranges from class 400 for densities of less than 1 pcf to

class 70 for densities of 15 pcf or greater2.


characteristics. Information of record for items 157455 and 157460 indicates a range in density

from 0.33 to 10.90 pcf, with an average density of 3.62 pcf.

Under CCSB policy, commodities exhibiting a wide range in density may be assigned

density-based classes; especially when there are no unusual handling, stowability or liability

characteristics.

Canceling items 157455 and 157460 and incorporating these commodities in item

157320, as proposed, is consistent with the aforementioned CCSB policy. The proponent also

believes this would eliminate interpretation disputes as to the proper classification of the

involved commodities, consistent with CCSB policy.

2 The CCSB’s standard nine-subprovision density scale includes reference to Item (Rule) 170, the

inadvertence clause, and Item (Rule) 171, the “bumping” privilege.


SUBJECT 9


Re: Waste Receptacles, steel or concrete

Staff Contact: Allison L. Austin Telephone — (703) 838-8864 [email protected]




99815 Holders or Receptacles, refuse, perforated steel or steel frame, with mounting

hardware, with or without wood slatted exterior, with or without

plastic or sheet steel liner, in boxes ................................................................ 100

99817 Holders or Receptacles, refuse or waste, cast concrete with wire

reinforcement, with or without tops or liners of other materials,

on pallets ............................................................................................................. 70

SHEET STEEL ARTICLES GROUP: subject to item 174300

174340 Baskets, NOI, Wastebaskets or Dry Measures, in packages:

Sub 1 Not nested ......................................................................................................... 200

Sub 2 Nested .................................................................................................................. 85

174540 Cans, ash, garbage, oiled waste, refuse, NOI, or disposal, with or without

bails or covers, in packages:

Sub 1 Nested, NOI, or not nested ............................................................................. 175

Sub 2 Nested, subject to Item 170 and having a density of 6 pounds or

greater per cubic foot ......................................................................... 125

175040 Receptacles, refuse or refuse bag, not over 12 cubic feet capacity, with

permanently attached tops or with self-closing tops, with or without

liners, in boxes or crates:

Sub 1 SU ........................................................................................................................ 125

Sub 2 KD flat ................................................................................................................... 70



99815 Holders or Receptacles, refuse, perforated steel or steel frame, etc .... Cancel; see

item B-NEW

99817 Holders or Receptacles, refuse or waste, cast concrete with wire

reinforcement, etc ............................................................................ Cancel; see

item A-NEW

A-NEW Receptacles or Holders, waste or refuse, cast concrete, with or without

tops, liners or mounting hardware of same or other materials, in

packages, subject to Item 170 and having a density in pounds per

cubic foot of:

Sub 1 Less than 12 ............................................................................................................. 125

Sub 2 12 or greater .............................................................................................................. 70


SUBJECT 9




SHEET STEEL ARTICLES GROUP: subject to item 174300

174340 Baskets, NOI, or Dry Measures, in packages:

Sub 1 Not nested .............................................................................................. No Change

Sub 2 Nested ..................................................................................................... No Change

174540 Cans, ash, garbage, oiled waste, refuse, NOI, or disposal, with or

without bails or covers, etc ........................................................ Cancel; see

item B-NEW

B-NEW Cans, Receptacles or Holders, waste or refuse, or Wastebaskets,

with or without tops, liners or mounting hardware of same

or other materials, see Note, item C-NEW, in boxes or crates ............. 175

C-NEW NOTE—Also applies on such products of steel frame construction, with

or without wood slatted exterior.

175040 Receptacles, refuse or refuse bag, not over 12 cubic feet capacity,

with permanently attached tops or with self-closing tops,

with or without liners, etc. ........................................................... Cancel; see

item B-NEW

Analysis


This proposal is based on information developed through Research Project 1143,

pertaining to waste or refuse cans, receptacles or holders, and wastebaskets. Herein these

products will be referred to as ―waste receptacles.‖

Research Project 1143 was initiated by the CCSB in October 2011, in light of existing

interpretation disputes. There are several waste receptacle entries in the NMFC™, with

provisions largely based on material consist and/or industry terminology. This proposal is limited

to waste receptacles constructed of steel or concrete.

It should be noted that the project originally encompassed waste receptacles of

aluminum or plastic construction as well. However, very limited data was obtained on

products made of these materials, and it is uncertain if the data received is representative of

the current transportation characteristics of those commodities. Consequently, this proposal

does not address aluminum or plastic waste receptacles.

Commodity questionnaires were sent to 343 potential manufacturers or shippers of

waste receptacles and three associations believed to represent those companies in October,

and for those that did not respond, again in December of 2011. Six questionnaires were

returned as undeliverable, 22 companies responded that they do not manufacture or ship

waste receptacles, three companies indicated that they do not ship via less-than-truckload

(LTL) and 29 companies provided information, 15 of which provided usable information on

steel or concrete waste receptacles. No responses were received from the associations

contacted.


SUBJECT 9


Additional information of record was developed through CCSB dock surveys, carrier-

submitted Shipment Information Forms and the CCSB’s Density Study1.


Item 99815, naming ―Holders or Receptacles, refuse, perforated steel or steel frame,‖

was established as a result of action taken on Subject 24 of Docket 797 (October 1979), and

first appeared in Supplement 7 to NMF 100-G, effective August 16, 1980. That proposal was

approved as modified; and information on that record indicated an average density of 9 pcf

and no unusual or significant handling, stowability or liability characteristics. The provisions

have remained substantially unchanged to the present.

Item 99817, naming ―Holders or Receptacles, refuse or waste, cast concrete with wire

reinforcement,‖ was established as a result of action taken on Subject 16 of Docket 812

(March 1981), and first appeared in Supplement 9 to NMF 100-H, effective October 10, 1981.

Information on that record indicated an average density of 40 pcf and no unusual or

significant handling or liability characteristics; although, some stowability issues were identified

due to the lack of a regular load-bearing surface for top freight. The proposal was approved

as modified, and the provisions have remained substantially unchanged to the present.

The noun ―Wastebaskets‖ was added to the description of item 174340, and the present

classes were established in the item, as a result of action taken on Subject 103 of Docket 74

(June 1956) and Subject 52 of Docket 77 (January 1957). The addition of the noun

―Wastebaskets‖ first appeared in Supplement 5 to NMFC A-4, effective August 12, 1958. The

present classes first appeared in Supplement 9 to NMFC A-4, effective November 4, 1958. The

provisions have remained substantially unchanged to the present.

The current subprovisions of item 174540, applying on sheet steel ―Cans, ash, garbage,

oiled waste, refuse, NOI, or disposal,‖ were established as a result of action taken on Subject

16 of Docket 898 (December 1989), and first appeared in Supplement 9 to NMF 100-P,

effective February 17, 1990. The proposal established a reduced class (125) for nested cans

having a density of 6 pcf or greater, per sub 2 of the item. Information on that record revealed

a density range of 6.32 to 13.8 pcf, with an average density of 8.44 pcf. There was no

indication of handling or stowability problems, and value per pound ranged from $0.72 to

$3.52, with an average of $1.50 (in 1989 dollars). Nested cans, NOI, or cans not shipped nested

remained at the previously assigned class (175), per sub 1.

The current provisions of item 175040, applying on sheet steel ―Receptacles, refuse or

refuse bag,‖ are a result of action taken on Subject 30 of Docket 803 (April 1980), and first

appeared in Supplement 9 to NMF 100-G, effective October 11, 1980. The proposal

established a reduced class (125) for receptacles shipped SU, per sub 1 of the item. Shipment






used.


SUBJECT 9


densities on that record ranged from 5.33 to 11.69 pcf, with a weighted average density of

7.41 pcf.

About Waste Receptacles

The involved commodities are waste receptacles constructed of steel or concrete. As

shown in the examples below, these waste receptacles vary in size, design and area of usage.

The products encompass those utilized in the public space, including on street corners, parks

and shopping malls, as well as those used in offices or homes. Although industry terminology

varies as to the name of these commodities they all serve comparable functions.

Shipments of Waste Receptacles

The photos below and on the next page illustrate just a few of the ways waste

receptacles are tendered for shipment.

Steel


SUBJECT 9


Concrete


Density—Overall, information of record includes 2,263 density observations for waste

receptacles. When these products are separated by material consist, 2,002 density figures

emerge for steel waste receptacles. The steel products range in density from 1.04 to 54.90 pcf,

with a simple average density of 5.48 pcf. A frequency distribution for steel waste receptacles

is shown below.

As the above frequency distribution depicts, the density observations for steel waste

receptacles are distributed throughout the range. However, over 87% of the figures are

between 2 and 8 pcf.

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

0.00%

3.60%

31.82%

28.02% 27.57%

4.35% 1.90% 1.05% 0.95% 0.40% 0.35% %

of

Fig

ure

s in

In

terv

al


Steel Waste Receptacles Frequency Distribution


SUBJECT 9


Information of record for concrete waste receptacles is based on 261 density figures.

These concrete products range in density from 4.22 to 64.29 pcf, with a simple average density

of 17.87 pcf. As shown in the frequency distribution below, while the densities are distributed

throughout the density range, there are two spikes, or clusters, of densities within the density

range. The first is the 6 but less than 8 pcf interval representing 18.39% of the density

observations, and the second is the 15 but less than 22.5 pcf interval representing 22.99% of

the density observations.

When the data for concrete waste receptacles is evaluated on the basis of the

proposed density break at 12 pcf, the following ranges and averages are calculated.

Density Group (pcf) Density Range (pcf) Average Density (pcf)

Less than 12 4.22 – 11.82 7.81

12 or greater 12.00 – 64.29 21.38

Handling—Waste receptacles are tendered for shipment in a variety of ways, including in

fiberboard boxes which may or may not be palletized, packaged in a crate, wrapped in

plastic film on a lift truck skid or pallet, strapped to a lift truck skid or pallet, or loose. Freight

boxed, crated or tendered on lift truck skids or pallets will generally provide better handling

than that tendered loose2. However, no unusual handling considerations have been reported.

2 While some of the involved products are shown to be tendered loose, the present provisions do not

authorize loose shipments.

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

0.00% 0.00% 0.00%

5.75%

18.39%

7.28% 6.51%

10.73%

22.99%

14.18% 14.18%

% o

f Fig

ure

s in

In

terv

al


Concrete Waste Receptacles Frequency Distribution


SUBJECT 9


Stowability—Generally, when tendered in boxes or crates, a flat load-bearing surface will be

present for loading other freight on top; however, some shippers instruct carriers to ―Do Not

Stack.‖ Greater stowability problems may exist when the waste receptacle is tendered

wrapped or strapped to a pallet or loose, as other freight may not be top-loaded because of

the absence of a regular load-bearing surface. Nevertheless, no specific stowability issues

have been reported by carriers.

Liability—Waste receptacles are not perishable, prone to spontaneous combustion or

explosion, or unusually susceptible to theft. One carrier that is unable to provide a claims ratio

specific to these products notes that dents and scratches to waste receptacles have been

reported when tendered loose or without sufficient interior packing materials. As is the case

with other general commodities, waste receptacles tendered in boxes, crates or on lift truck

skids or pallets will be afforded greater protection against damage than those tendered loose.

When necessary, per Item (Rule) 680, Sec. 1(a), interior packing must be provided to give

adequate protection against damage to the freight.

A second carrier reports a claims ratio of 0.06% for product shipments moving under

item 99815 and 0.55% for shipments moving under item 99817, both below the 1% threshold

considered typical for LTL freight operations. Responding shippers have indicated a limited

number of claims on these commodities.

A limited amount of information on the value of these commodities reveals a range

from $1.12 to $43.54 per pound, with an average value of $7.24 per pound for steel waste

receptacles, and a range from $0.77 to $3.25 per pound, with an average value of $1.63 per

pound for concrete waste receptacles.


CCSB policy calls for provisions to be as clear as possible to mitigate the potential for

interpretation disputes, combining descriptions embracing related commodities and uniformity

in provisions addressing the same or similar circumstances.

The present language and structure of provisions applying on waste receptacles is

incongruous. Items 99815, 174340, 174540 and 175040 all apply on waste receptacles

constructed of steel, but are inconsistently named and described throughout the

Classification, resulting in interpretation issues. These interpretation issues could be mitigated

by combining the descriptions for the related commodities. Combining these related

commodities for simplification and uniformity would be in keeping with CCSB policy.

CCSB policy also calls for provisions to reflect a commodity’s known transportation

characteristics. Information of record for steel waste receptacles shows a range in density from

1.04 to 54.90 pcf, with an average density of 5.48 pcf. As shown in the frequency distribution

on page 5, a predominant concentration of density figures for steel waste receptacles are

within a narrow range around the overall average. Under CCSB guidelines, an average

density of 5.48 pcf is generally associated with a class 175, which calls for a minimum average

density of 5 pcf.


SUBJECT 9


Removing ―Wastebaskets‖ from item 174340 and canceling items 99815, 174540 and

175040 with reference to a new item for sheet steel ―Cans, Receptacles or Holders, waste or

refuse, or Wastebaskets,‖ at class 175, reflective of the overall average density of these

commodities, would be in keeping with CCSB policy and precedent.

Such an approach would be consistent with action taken on Docket 2009-3, Subject 2

(October 2009), involving item 28160, for footwear. No significant negative handling,

stowability or liability concerns were reported, and, as such, density was determined to be the

primary transportation characteristic. As with steel waste receptacles, footwear was shown to

exhibit a wide range of densities—from 1.00 to 50.00 pcf—with a significant concentration of

the density observations—almost 78%—clustered around the overall average density of 6.28

pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal

was approved as docketed, assigning class 150, and the provisions first appeared in

Supplement 5 to NMF 100-AI, effective January 9, 2010.

A new Note would also be added to provide for waste receptacles on a steel frame,

with or without a wood slatted exterior.

Information of record for concrete waste receptacles reveals a range in density from

4.22 to 64.29 pcf, with an average density of 17.87 pcf. According to CCSB density guidelines,

an average density of 17.87 pcf is generally associated with a class 70, which calls for a

minimum average density of 15 pcf. However, CCSB policies further 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. As shown in the frequency distribution on page

6, there are two spikes, or clusters, of densities within the overall density range. When the data

of record is evaluated on that basis, with a density break at 12 pcf, the following density

groupings and class assignments emerge.

Density Group (pcf) Average Density (pcf) Guideline Class Density Guideline

(pcf)

Less than 12 7.81 125 7

12 or greater 21.38 70 15

Canceling the provisions of item 99817, for cast concrete waste receptacles, and

establishing a new item for ―Receptacles or Holders, waste or refuse, cast concrete,‖ with a

density break at 12 pcf3, reflective of the two spikes within the overall density range, would be

in keeping with CCSB policy and precedent.

A similar approach was taken on Docket 2009-2, Subject 11 (June 2009), involving

engine radiator, fuel tank or oil filler caps, as named in item 116430. No significant negative

handling, stowability or liability concerns were reported, and, as such, density was determined

to be the primary transportation characteristic. While the densities were distributed throughout

the density range of 2.96 to 67.74 pcf, there were two spikes, or clusters, of densities within the

overall density range. Thus, a single density break was proposed to provide a more accurate

reflection of the identified range in density. That proposal was approved as docketed, and the

provisions first appeared in Supplement 3 to NMF 100-AI, effective August 22, 2009.



SUBJECT 9







SUBJECT 10


Re: Partitions or Partition Doors, steel and wire combined





BUILDING METALWORK GROUP: subject to item 35600

36890 Partitions or Partition Doors, steel and wire combined, in sections or panels .. 77.5

FENCING GROUP: subject to item 68000

68025 Fencing, NOI, or Fence Gates, other than plastic, in packages, subject to

Item 170 and having a density in pounds per cubic foot of:

Sub 1 Less than 8 ......................................................................................................... 200

Sub 2 8 but less than 12 .............................................................................................. 110

Sub 3 12 or greater ........................................................................................................ 77.5




36890 Partitions or Partition Doors, steel and wire combined, etc ............... Cancel; see

item 68025

FENCING GROUP: subject to item 68000

68025 Fencing, NOI, or Fence Gates, other than plastic; or Partitions or Partition

Doors, steel and wire combined; in packages, subject to Item 170

and having a density in pounds per cubic foot of:

Sub 1 Less than 8 ......................................................................................................... 200

Sub 2 8 but less than 12 .............................................................................................. 110

Sub 3 12 or greater ........................................................................................................ 77.5

Analysis

This proposal originated from Research Project 1160, which was initiated in March, 2012

in response to an interpretive request from a member carrier questioning whether or not steel

and wire partitions are properly classified as fence panels, per item 68025, or as partitions, per

item 36890 (as held by the CCSB). Information submitted by the carrier indicated densities

between 6 and 8 pcf for shipments tendered on lift truck skids or pallets, which is inconsistent

with the currently assigned class 77.5 provided in item 36890. CCSB guidelines for class 77.5 call

for a minimum average density of 13.5 pcf.


During the course of Research Project 1160, questionnaires regarding the transportation

characteristics of partitions or partition doors of steel and wire construction were sent to 12


SUBJECT 10


associations and 67 potential manufacturers or shippers in May, and for non-respondents, July

of 2012. From these mailings, only one shipper furnished any usable information. One

association, the Steel Manufacturers Association, confirmed their members are involved with

the transportation of the subject commodities, but did not provide any data. Additional

information was developed through the CCSB‘s Density Study1 and dock surveys, along with

carrier-submitted reports.


Provisions for partitions or partition doors of steel and wire construction were adopted

from the rails in 1936. The entry has remained substantially unchanged save for the removal of

the term ‗flat‘ from the description to address possible interpretative difficulties with shipments

in sections or panels. This change was the result of action taken on Subject 132 of Docket 125

(September, 1966), and first appeared in Supplement 9 to NMFC A-9, effective May 17, 1967.

Item 68025 was established as a result of action taken on Subject 1 of Docket 898

(December, 1989), which established the Fencing Group as a new generic grouping. The

current provisions were established as a result of action taken on Docket 2009-1, Subject 1

(February, 2009). Most notably, item 68028 was established and restricted to wire fencing in

rolls, while item 68025 was amended as an ‗NOI‘ entry to cover all other forms, including

shipments in panels or sections. The provisions first appeared in Supplement 2 to NMF 100-AI,

effective April 25, 2009.

About Partitions or Partition Doors

Steel and wire mesh partitions as named in item 36890 are modular units that, like fence

panels, provide a defined space and/or provide security for a variety of applications. They

can resemble cages or enclosures, depending upon how and where used, and are

assembled from panels or sections, with one or more doors. Typical examples include storage

or service enclosures, tool cribs, robotic barriers, or pharmaceutical cages, as depicted below.

Interpretations initially held the products to be classified as fencing, per item 68025, but later

upon reconsideration those opinions were rescinded and the products were held to be

classified under the specific provisions of item 36890.






used.


SUBJECT 10



Density—The information of record includes 533 density figures ranging from 1.25 to 88.30 pcf,

for an average of 9.39 pcf. As depicted in the graph below, the densities are distributed

throughout the range.

A comparison of fence panels or gates (from the record of Docket 2009-1, Subject 1)

and partitions or partition doors is shown below.

Table 1 – Fence Panels or Gates

Density Group

(pcf)

Density Range

(pcf)

Average

Density (pcf)

Less than 8 1.15 – 7.98 5.75

8 but less than 12 8.00 – 11.98 9.88

12 or greater 12.00 – 141.89 19.83

Table 2 – Partitions or Partition Doors

Density Group

(pcf)

Density Range

(pcf)

Average

Density (pcf)

Less than 8 1.25 – 7.96 5.17

8 but less than 12 8.01 – 11.94 9.58

12 or greater 12.05 – 88.30 20.77

Handling—Carrier reports indicate that product shipments can exceed 96 inches in length.

Generally, freight that exceeds 96 inches in length will require extra care and attention during

handling.

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

0.00% 0.38%

12.59% 14.47%

16.17%

28.57%

12.41%

6.39% 5.45%

1.88% 1.69%

% o

f Fig

ure

s In

In

terv

al




SUBJECT 10


Stowability—Just as with fencing, when tendered in an upright position or without protective

packaging on lift truck skids or pallets, partitions may be more difficult to stow than general

boxed freight. Carriers may be restricted to floor loading and might not be able to stack

freight on top due to the lack of a load-bearing surface. Some shipments are labeled with

precautionary markings or instructions such as ―Do Not Double Stack.‖

Liability—These commodities are not perishable, susceptible to theft or prone to spontaneous

combustion or explosion. They may be liable to damage during transit when tendered on lift

truck skids or pallets and not adequately protected by packaging.

The value per pound is unknown, while carrier claims personnel did not indicate any

claims issues.


CCSB policy calls for establishing or amending classification provisions for commodities

that are a source, or potential source, of interpretation disputes so as to eliminate or avoid

those disputes. CCSB policy also calls for combining descriptions embracing related

commodities. As mentioned, there has been some question as to the applicable NMFC™

provisions for the subject commodities; in particular, between item 36890, which names

partitions or partition doors, and item 68025, which names fencing or fence gates. The terms

apply on very similar, if not identical, articles. Canceling item 36890 with reference to item

68025, and naming steel and wire partitions or partition doors in item 68025, as proposed,

would address the interpretation issue.

It is also CCSB policy that provisions reflect a commodity‘s known transportation

characteristics. The information of record shows that partitions or partition doors exhibit a

density range from 1.25 to 88.30 pcf, for an average of 9.39 pcf, along with some handling,

stowability and liability concerns. The density range is consistent with the range of densities

considered in the establishment of the present provisions in item 68025 for fencing or fence

gates2, along with comparable handling, stowing and liability characteristics. (A

commensurate one-class adjustment was made to item 68025 to reflect the impact of

negative handling, stowing and liability concerns.) A comparison of fence panels or gates

(from the record of Docket 2009-1, Subject 1) and partitions or partition doors is shown on the

next page.

2 The density-based provisions of item 68025 include reference to Item (Rule) 170, the inadvertence

clause.


SUBJECT 10


Table 3 – Fence Panels or Gates

Density Group

(pcf)

Density

Range (pcf)

Average

Density (pcf)

Class Based on

CCSB

Guidelines

Class Based on

One-Class

Increase

Less than 8 1.15 – 7.98 5.75 175 200

8 but less than 12 8.00 – 11.98 9.88 100 110

12 or greater 12.00 – 141.89 19.83 70 77.5

Table 4 – Partitions or Partition Doors

Density Group

(pcf)

Density

Range (pcf)

Average

Density (pcf)

Class Based on

CCSB

Guidelines

Class Based on

One-Class

Increase

Less than 8 1.25 – 7.96 5.17 175 200

8 but less than 12 8.01 – 11.94 9.58 100 110

12 or greater 12.05 – 88.30 20.77 70 77.5

For these reasons, this proposal is consistent with CCSB policy and precedent.




SUBJECT 11


Re: Screen Doors or Window Screens






35310 Screens, window, adjustable, metal screen cloth in frames consisting of

metal top and bottom members (rails) and wooden ends, in boxes .. 85


37080 Screen Doors or Window Screens, NOI, see Note, item 37082, in packages . 125

37082 NOTE—Shipments in bundles must have screening protected.

37085 Screens or Barriers, window or door, detention or security, see Note, item

37087, in packages ...................................................................................... 70

37087 NOTE—Applies only on metal frames with wire cloth or perforated metal

screening used on building windows or doors to provide security,

protection or safety.

37090 Screens, window, tension type, not framed, aluminum or aluminum with

steel wire screen cloth, in boxes ............................................................... 100

BUILDING WOODWORK GROUP: subject to item 37500

37930 Frames, screen door or window screen, wooden, KD, with or without

metal fittings, in packages .......................................................................... 70

38150 Screen Doors or Window Screens, see Note, item 38152, in packages ......... 100

38152 NOTE—Shipments in bundles must have screening protected.




35310 Screens, window, adjustable, metal screen cloth in frames consisting

of metal top and bottom members (rails) and wooden

ends, etc ....................................................................................... Cancel; see

item A-NEW

A-NEW Screen Doors or Window Screens, NOI; or Screens or Barriers, door

or window, detention or security, see Note, item B-NEW; in boxes or

crates, subject to Item 170 and having a density in pounds per

cubic foot of:

Sub 1 Less than 6 ......................................................................................................... 300

Sub 2 6 but less than 10 .............................................................................................. 150

Sub 3 10 or greater ........................................................................................................ 85

B-NEW NOTE—Applies on metal frames with wire cloth or perforated metal screening

used on building doors or windows to provide security, protection or

safety.


SUBJECT 11





37080 Screen Doors or Window Screens, NOI, etc ......................................... Cancel; see

item A-NEW


37085 Screens or Barriers, window or door, detention or security, etc ....... Cancel; see

item A-NEW

37087 NOTE—Cancel; see item B-NEW.

37090 Screens, window, tension type, not framed, aluminum or aluminum

with steel wire screen cloth, etc ................................................ Cancel; see

item A-NEW

BUILDING WOODWORK GROUP: subject to item 37500

37930 Frames, screen door or window screen, wooden, KD, with or without

metal fittings, etc ......................................................................... Cancel; see

item A-NEW

38150 Screen Doors or Window Screens, etc ................................................. Cancel; see

item A-NEW


Analysis


This proposal is based on information developed through Research Project 1139, which

was initiated in August 2011 to investigate the transportation characteristics of screen doors or

window screens, as classified in items 35310, 37080, 37085, 37090, 37930 and 38150. As part of

the research, 513 potential manufacturers or shippers and nine trade associations were

contacted in January 2012, and for those that did not respond, again in April 2012, inviting

them to participate. From this sampling, 31 of the shipper surveys were returned as

undeliverable, 67 companies responded that they did not manufacture or ship the involved

articles, and 10 companies provided at least some information. Not all of the information was

usable, however. With respect to the associations, one survey was returned as undeliverable,

three associations responded that they did not represent manufacturers or shippers of the

involved articles, and one association refused delivery of the survey. No response was

received from the remaining four associations.


The provisions of item 35310, applying on “Screens, window, adjustable, metal screen

cloth in frames consisting of metal top and bottom members (rails) and wooden ends,” were

established as a result of action taken on Docket 722, Subject 54 (March 1972). That was a

proposal to establish a specific provision for these screens in lieu of them being classified under

item 37080, “Screen Doors or Window Screens, NOI.” The proposal was approved as modified,

and the provisions first appeared in Supplement 4 to NMF 100, effective March 2, 1973.


SUBJECT 11


The current provisions of item 37080, applying on metal “Screen Doors or Window

Screens, NOI,” and item 37085, applying on “Screens or Barriers, window or door, detention or

security,” were established as a result of action taken on Docket 964, Subject 8 (November

1996). That was a proposal to amend item 37080 to remove its reference to “other than

detention or roller,” and to amend item 37085 to name “Screens or Barriers, window or door,

detention or security.” The proposal was approved as docketed, and the changes first

appeared in Supplement 6 to NMF 100-W, effective January 18, 1997.

The current provisions of item 37090, applying on “Screens, window, tension type, not

framed, aluminum or aluminum with steel wire screen cloth,” were established as a result of

action taken on Docket 58, Subjects 63 and 77 (April 1953), and first appeared in Supplement

17 to NMFC A-1, effective November 17, 1953. The supporting documentation for this change

is no longer available.

The provisions of item 37930, “Frames, screen door or window screen, wooden, KD, with

or without metal fittings,” were adopted from the rails in 1936 and have remained substantially

unchanged to the present.

The current provisions of item 38150, for wooden “Screen Doors or Window Screens,”

were established as a result of action taken on Docket 138, Subject 56 (January 1969), and first

appeared in Supplement 29 to NMFC A-10, effective January 21, 1970.

About Screen Doors and Window Screens

Screen doors and window screens are used in houses and other buildings to keep

insects and other pests out while allowing light and air to enter. They may be fixed in place,

like many window screens, or hinged or on wheels to allow egress into and out of the structure.

Screen doors or window screens are generally made from a metal or wood frame with either

aluminum or fiberglass mesh in the frame opening. (Detention or security screens or barriers

tend to be of more-robust construction.) Their size will vary depending upon the application.


Density—The information of record encompasses 1,631 density observations from a variety of

sources, including shipper- and carrier-supplied data, CCSB dock surveys, and the CCSB’s

Density Study1. The densities range from 0.60 to 81.49 pcf, with a simple average density of

8.06 pcf. A frequency distribution of the overall density range is provided on the following

page.






used.


SUBJECT 11


As can be seen in the density distribution, while the densities are distributed throughout

the range, they are grouped within three clusters of less than 6 pcf, 6 but less than 10 pcf, and

10 pcf or greater. The table below provides an evaluation of the densities on the basis of

these three density groups.

Density Group (pcf) Density Range (pcf) Average Density (pcf)

Less than 6 0.60 to 5.99 3.62

6 but less than 10 6.00 to 9.99 7.76

10 or greater 10.00 to 81.49 14.57

The table below provides a breakdown of the densities of record on the basis of the

reportedly applicable item number.

Item Number Density Range (pcf) Average Density (pcf)

35310 1.50 to 54.05 8.24

37080 0.60 to 35.51 5.71

37085 2.09 to 81.49 11.04

37090 1.75 to 46.25 8.06

37930 4.05 to 24.44 9.07

38150 1.03 to 50.00 10.29

As depicted in the table above, the density ranges for each item overlap.

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

14.00%

16.00%

18.00%

20.00%

0.49%

5.70%

19.13% 19.37%

13.86%

9.87%

17.96%

5.33% 5.21%

1.53% 1.53%

% o

f Fig

ure

s in

In

terv

al




SUBJECT 11


Handling—Screen doors and window screens are generally lightweight and may require extra

care and attention when loading, unloading and in cross-dock operations. The information

developed indicates that most screen doors and window screens are tendered in boxes that

may be palletized for shipment. When palletized they are frequently placed within a wooden

framework built on or around the pallet or in an A-frame-type shipping container. Many of the

packages provide directional arrows and other handling instructions. While not appearing to

be the norm, not all screen doors or window screens are tendered on pallets or provide for

mechanical handling.

Stowability—Information of record indicates that screen doors or window

screens are packaged and tendered for shipment in different manners,

including secured flat on pallets, mounted on edge on pallets, or enclosed

within packaging material but not on pallets. When mounted on edge,

screen doors or window screens are typically braced with diagonal bracing

resembling an A-frame-type package, or with some other method of bracing

to support the screen in position. Regardless of the manner in which the

screen door or window screen is tendered for shipment, several negative

stowing considerations have been identified.

When placed flat on a pallet, extra care and attention will have to be given to ensure

that any freight loaded on top of the screen doors or window screens is compatible to

minimize the potential for damage.

Screen doors or window screens mounted on edge, whether or not on a pallet, will lack

a flat load-bearing surface for other freight. The impact of this on the

carrier’s ability to load other freight may be lessened somewhat due to

the height of the screen, especially in the case of screen doors;

nevertheless, the space above the package is essentially unusable.

Screen doors or window screens tendered in this manner will also

typically require floor loading, which will further inhibit the carrier’s ability

to utilize available vehicle space due to the inability to tier shipments.

As previously mentioned, the involved screen doors or window screens are also often

mounted on a pallet and a supporting framework is built around them. This framework may

consist of diagonally affixed boards to support the screen, or some type of vertical framework,

and often results in an irregularly shaped package.


SUBJECT 11


The manner in which the screen door or window screen is

packaged and tendered to the carrier for shipment presents not only

negative stowing considerations due to the inability to efficiently use the

available vehicle space, it also has a detrimental impact on the density of

the screen. Additionally, screen doors or window screens tendered in this

manner will require extra care and attention when loading freight

adjacent to them to ensure that shifting during transit does not occur,

which might break the supports or damage the screen, especially as these

packages offer little or no lateral support to adjacent freight. This increases the difficulty in

structuring the load within the vehicle.

Liability—Screen doors or window screens are not perishable, prone to spontaneous

combustion or explosion or unusually susceptible to theft. With respect to damage, screen

doors and window screens may be somewhat susceptible to damage, especially to denting,

tearing and abrasion from adjacent freight.

Additionally, the manner in which a screen door or window screen is tendered for

shipment may also have an impact on its susceptibility to damage. As depicted in the

photographs throughout this analysis, many of the methods employed by shippers when

packaging their screen doors or window screens do not provide any lateral support for other

freight. This is because the screen is mounted vertically in the center or on the edge of a

pallet and is supported by bracing. This bracing may be of sufficient strength to hold the

screen door or window screen in position, but it may not support the additional load placed

on it by adjacent freight. This could result in damage to the screen. There is, however, no

indication of a claims problem. A limited amount of information on the value of screen doors

or window screens indicates a range from $3.16 to $4.29 per pound, with an average value of

$3.72 per pound.



characteristics. Information of record reveals that screen doors or window screens are

shipped in a variety of different configurations, resulting in a density range from 0.60 to 81.49

pcf. CCSB policy further provides that where commodities or commodity groups exhibit a

wide density range not accurately reflected by a single, overall average density, they may be

assigned density-based classes. However, in this instance research has identified several

significant negative handling, stowability and liability considerations that must also be

considered, in accordance with CCSB policies. These have been detailed in the analysis and

include such factors as the lack of a flat load-bearing surface and lack of lateral support for

other freight.

CCSB policy also calls for commodity descriptions to be as clear as possible to help

preclude interpretation disputes. The currently applicable provisions are primarily based on

the material consist of the screen door or window screen. However, screen doors or window

screens are made from a variety of materials, including combinations of different materials,

which may not be reflected by the existing provisions. This can result in interpretation issues as

it may be difficult to determine the material consist of a given screen door or window screen

by visual inspection. Establishing a new item for “Screen Doors or Window Screens, NOI; or


SUBJECT 11


Screens or Barriers, door or window, detention or security,” with no restrictions as to material

consist, and canceling items 35310, 37080, 37085, 37090, 37930 and 38150 with reference to

the new item, as proposed, is in keeping with CCSB policy.

Furthermore, in view of the information of record, it would be in keeping with CCSB

policy and classification precedent to establish provisions based on density, as proposed2. As

detailed in the discussion of density, the density figures are distributed in three clusters or

groupings of less than 6 pcf, 6 but less than 10 pcf, and 10 pcf or greater. The following table

provides an evaluation of the density information of record on the basis of the three proposed

density groups and shows the density range and average density associated with each group,

the class according to CCSB density guidelines, the CCSB density guideline for that class, and

a one-class increase to reflect the identified negative handling, stowing and liability

considerations.

Density Group

(pcf)

Density

Range (pcf)

Average

Density (pcf)

Class per CCSB

Density

Guidelines

CCSB

Density

Guideline

(pcf)

Proposed

Class

Less than 6 0.60 to 5.99 3.62 250 3 300

6 but less than 10 6.00 to 9.99 7.76 125 7 150

10 or greater 10.00 to 81.49 14.57 77.5 13.5 85

With respect to commodities that exhibit less-than-favorable handling, stowability or

liability characteristics, CCSB precedent has been to assign a class higher than what would

generally be called for under the density guidelines. A recent example of such an approach

can be found in Docket 2009-1, Subject 1 (February 2009) involving fencing. In that instance,

the CCSB approved provisions based on density in item 68025 due to the range of densities

exhibited; however, the class assigned to each density group was one class higher than what

would be called for under CCSB guidelines to reflect identified negative handling, stowing

and liability considerations.







SUBJECT 12


Re: Electrical Switch Boxes, Conduit Outlet Boxes or Outlet Box Covers, steel, not exceeding 12

united inches—Item 61057






61057 Boxes, switch or conduit outlet or Outlet Box Covers, other than outlet box

plates, steel, plain, primed or galvanized, outside measurement of

boxes not exceeding 12 united inches (length, width and depth

added), with or without fittings or covers, see Note, item 62682, in

packages....................................................................................................... 55

62682 NOTE—Applies only on articles named when without electrical equipment such

as switches or receptacles.



SUBJECT 12





63160* Switch Boxes, Electrical Enclosures or Electrical Wiring Equipment, viz.:

Electric Meter Sockets;

Electrical Enclosures, NOI;

Junction Boxes or Cabinets;

Outlet Box Covers, other than outlet box plates;

Outlet Boxes;

Switch Boxes, NOI;

Terminal Boxes or Housings;

Terminal or Junction Blocks;

Terminals, electrical cable or wiring, NOI, including Connectors or

Butt Splices, see Note, item 63163;

With or without fittings, see Note, item 63162, in boxes, see Note,

item 63161, subject to Items 170 and 171 and having a density

in pounds per cubic foot of:

Sub 1 Less than 1 ............................................................................................. 400

Sub 2 1 but less than 2 .................................................................................... 300

Sub 3 2 but less than 4 .................................................................................... 250

Sub 4 4 but less than 6 .................................................................................... 150

Sub 5 6 but less than 8 .................................................................................... 125

Sub 6 8 but less than 10 .................................................................................. 100

Sub 7 10 but less than 12 .................................................................................. 92.5

Sub 8 12 but less than 15 .................................................................................. 85

Sub 9 15 but less than 22.5 ............................................................................... 70

Sub 10 22.5 but less than 30 ............................................................................... 65

Sub 11 30 or greater ............................................................................................ 60


63162* NOTE—Not involved.


*Published in Supplement 4 to NMF 100-AL, issued on November 1, 2012 with an effective date

of December 1, 2012.




61057 Boxes, switch or conduit outlet or Outlet Box Covers, other than outlet box

plates, steel, plain, primed or galvanized, outside measurement of

boxes not exceeding 12 united inches (length, width and depth

added), etc .................................................................................. Cancel; see

item 63160



SUBJECT 12





63160 Switch Boxes, Electrical Enclosures or Electrical Wiring Equipment, viz.:

Electric Meter Sockets;

Electrical Enclosures, NOI;

Junction Boxes or Cabinets;

Outlet Box Covers, other than outlet box plates;

Outlet Boxes;

Switch Boxes, NOI;

Terminal Boxes or Housings;

Terminal or Junction Blocks;

Terminals, electrical cable or wiring, NOI, including Connectors or

Butt Splices, see Note, item 63163;

With or without fittings, see Note, item 63162, in boxes, see Note,

item 63161, subject to Items 170 and 171 and having a density

in pounds per cubic foot of:

Sub 1 Less than 1 ............................................................................................. 400

Sub 2 1 but less than 2 .................................................................................... 300

Sub 3 2 but less than 4 .................................................................................... 250

Sub 4 4 but less than 6 .................................................................................... 150

Sub 5 6 but less than 8 .................................................................................... 125

Sub 6 8 but less than 10 .................................................................................. 100

Sub 7 10 but less than 12 .................................................................................. 92.5

Sub 8 12 but less than 15 .................................................................................. 85

Sub 9 15 but less than 22.5 ............................................................................... 70

Sub 10 22.5 but less than 30 ............................................................................... 65

Sub 11 30 or greater ............................................................................................ 60




Analysis

As a result of action taken on Docket 2012-2, Subject 2 (May 2012), the provisions of

former item 63170, for steel switch boxes or electrical enclosures, conduit outlet boxes or

junction boxes or cabinets, or outlet box covers, were canceled with reference to item 63160,

which applied on the same products constructed of other materials. (The restriction on

material construction was concurrently removed from item 63160.) These changes were first

published in Supplement 2 to NMF 100-AL, effective July 21, 2012. The intent of that proposal—

in addition to assigning classes reflective of the products’ transportation characteristics—was

to combine the provisions for these similar commodities in the interest of clarification and

simplification. Subsequent to the docketing of that proposal, the CCSB became aware of an

additional item (61057), applying on steel switch boxes, conduit outlet boxes or outlet box

covers, not exceeding 12 united inches.


SUBJECT 12


The provisions of item 61057 were established as a result of action taken on Docket 99,

Subject 34 (June 1961), and first appeared in Supplement 15 to NMFC A-5, effective

November 16, 1961. The current class 55 was established as a result of action taken on Docket

811, Subject 2 (January 1981). Information on that record revealed a density range of 26.80 to

288.10 pcf, with an average density of 64.50 pcf. There was no indication of handling or

stowability problems, and value per pound ranged from $0.24 to $1.02, with an average of

$0.46 (in 1981 dollars). That proposal was approved as modified, and the change first

appeared in Supplement 12 to NMF 100-H, effective January 4, 1982.

While item 61057 was not directly involved in Subject 2 of Docket 2012-2, all steel switch

boxes, conduit outlet boxes or outlet box covers, regardless of size, were included in Research

Project 1135, on which that proposal was based. Moreover, a review of item 61057, using the

CCSB Density Study1, finds densities ranging from 4.40 to 33.82 pcf, with an average density of

11.25 pcf. This is inconsistent with the density data considered when the current class 55 was

assigned, and it is inconsistent with CCSB guidelines for the current class 55, which call for a

minimum average density of 35 pcf. The average density of 11.25 pcf is, however, comparable

to the average density of 11.60 pcf on the record of Docket 2012-2, Subject 2, and the density

range of 4.40 to 33.82 pcf is both wide and within the range of 0.08 to 140.62 pcf identified on

the record of Docket 2012-2, Subject 2.


CCSB policy calls for combining descriptions embracing related commodities in the

interest of clarification and simplification. The intent of Docket 2012-2, Subject 2, was to cancel

the provisions for steel switch boxes or electrical enclosures, conduit outlet boxes or junction

boxes or cabinets, or outlet box covers, and classify such articles under the same provisions as

those of all other materials, with classes reflective of their transportation characteristics.

Despite considering all steel products during the research project, the provisions of item 61057,

applying on steel switch boxes, conduit outlet boxes or outlet box covers, contingent on size,

were overlooked in that proposal. Based on the information of record, canceling item 61057

with reference to item 63160, as proposed, would be in keeping with CCSB policy and the

intent of Docket 2012-2, Subject 2.

This proposal, as docketed, is in keeping with CCSB policy and precedent.






used.


SUBJECT 13


Re: Item (Rule) 110, Sec. 8, Determination of Density

Staff Contact: Donald A. Newell Telephone — (703) 838-1890 [email protected]



ITEM 110

DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES

The following definitions will apply when such terms are used in this Classification or in tariffs

governed by this Classification. When different definitions are provided for the same terms in

connection with rates, classes, rules or other provisions, such definitions will take precedence.

Secs. 1-7. (c) Not Involved.

Sec. 8. ‘Density.’ Where classes are applicable according to the density of articles as

tendered for shipment, the word 'density' means 'pounds per cubic foot.'

Sec. 8. (a) To determine the density of an article, first determine the cubage by multiplying

the greatest straight-line dimensions of length, width and height (depth) in inches, including all

projections, of the article as tendered to the carrier for shipment, and dividing the total by

1,728 cubic inches (one cubic foot). The density is the result of the division of the weight of the

article as tendered for shipment by the cubic feet. For instance, the density of a box

measuring 12" x 12" x 30" and weighing 10 pounds is determined as follows: 12" x 12" x 30" =

4,320 cubic inches; 4,320 ÷ 1728 = 2.50 cubic feet; 10 lbs. ÷ 2.50 = 4.00 pounds per cubic foot

(pcf).

Sec. 8. (b) To determine the density of a cylindrical-shaped article, square the greatest

dimension on the cylindrical plane by multiplying the dimension by itself in inches and then

multiplying that result by the height or length. Divide the result by 1,728 cubic inches. The

density is the result of the division of the weight of the article by the cubic feet.

Sec. 8. (c) Where articles are unitized on lift truck pallets, platforms, racks or skids, the pallet,

platform, rack or skid constitutes the shipping package, or a part thereof, and except as

provided in Item 640, Sec. 3 (b), must be included in the computation of density.

Secs. 9-22. Not Involved.



SUBJECT 13



ITEM 110

DEFINITIONS AND EXPLANATIONS OF TERMS, PUNCTUATION AND REFERENCES

The following definitions will apply when such terms are used in this Classification or in tariffs

governed by this Classification. When different definitions are provided for the same terms in

connection with rates, classes, rules or other provisions, such definitions will take precedence.

Secs. 1-7. (c) No Change.

Sec. 8. ‘Density.’ Except as otherwise provided, where classes are based on the density

of articles as tendered for shipment, the word ‘density’ refers to the actual density of each

handling unit so tendered, as measured in pounds per cubic foot. (See Sec. 8 (c).)

Sec. 8. (a) To determine the density of each handling unit, first determine the cubage

of the handling unit by multiplying the greatest straight-line dimensions of length, width and

height (depth) in inches, including all projections, if any, as tendered to the carrier for

shipment, and dividing the total by 1,728 cubic inches (one cubic foot). The density is the result

of the division of the weight of the handling unit as tendered for shipment by the cubic feet.

For instance, the density of a handling unit consisting of boxes unitized on a lift truck pallet

measuring 48" x 40" x 45" and weighing 450 pounds is determined as follows: 48" x 40" x 45" =

86,400 cubic inches; 86,400 ÷ 1,728 = 50 cubic feet; 450 lbs. ÷ 50 = 9.00 pounds per cubic foot

(pcf).

Sec. 8. (b) To determine the density of a cylindrical-shaped handling unit, square the

greatest dimension on the cylindrical plane by multiplying the dimension by itself in inches and

then multiplying that result by the height or length. Divide the result by 1,728 cubic inches. The

density is the result of the division of the weight of the handling unit by the cubic feet.

Sec. 8. (c) Where articles are unitized on lift truck pallets, platforms, racks or skids, the pallet,

platform, rack or skid constitutes an integral part of the handling unit, and except as

provided in Item 640, Sec. 3 (b), must be included in the computation of density.

Secs. 9-22. No Change.

Analysis

Over the years there have been many requests to clarify the determination of density

for shipments consisting of multiple handling units. Specifically, interpretation requests have

come from shippers, carriers and logistics companies asking if the density of each handling

unit must be determined.

Interpretations have consistently held that, except as otherwise provided, density

should be determined for each handling unit based on its dimensions and weight as tendered,

and not based on the total cube and weight of all such handling units in the shipment.

A recent inquiry from a member carrier indicates that this remains an interpretive

difficulty for many users of the NMFC™. This proposal would amend Item (Rule) 110, Sec. 8 to

clarify how density is to be determined, where the class is predicated on density in the

NMFC™, and so eliminate much of the interpretive difficulty.


SUBJECT 13



CCSB policy is to maintain rules that are clear as to intent. This proposal seeks to clarify

the intent and application of Item (Rule) 110, Sec. 8 regarding determination of density for

shipments consisting of multiple handling units. Based on the information of record, this

proposal, as docketed, is in keeping with CCSB policy.




SUBJECT 14


Re: Siding, plastic—Item 170580





ROOFING OR SIDING MATERIALS GROUP: subject to item 170000

170580 Siding, plastic, other than with expanded plastic or rubber backing or

insulation, see Notes, items 170582 and 170583, in boxes or

Package 2041 ............................................................................................... 70

170582 NOTE—Will also apply on fittings or accessorial articles for installation, including

corner posts, not exceeding 10 percent of the weight upon which

charges are assessed.

170583 NOTE—For classes applicable to plastic siding combined with expanded

plastic or rubber backing or insulation, see item 156600.



ROOFING OR SIDING MATERIALS GROUP: subject to item 170000

170580 Siding, plastic, other than expanded plastic and other than with expanded

plastic or rubber backing or insulation, see Notes, items 170582 and

170583, in boxes or Package 2041 ............................................................. 70


170583 NOTE—For classes applicable to plastic siding combined with expanded

plastic or rubber backing or insulation, see item 156600. For classes

applicable to expanded plastic siding, see item 157320.

Analysis

In an effort to update and improve the usability of the National Motor Freight

Classification™, the CCSB continually reviews and considers changes to ensure that NMFC™

provisions are clear as to intent and reflect industry standards.

In this respect, there have been a couple of approved changes to the provisions of

item 170580, applying on plastic siding. Specifically, the modifying phrase “clapboard style”

was dropped for clarification purposes, and the entry was simply left to apply on plastic

siding1. Subsequent interpretation inquiries revealed variations on plastic siding combined with

expanded plastic or rubber backing or insulation. Consequently, action was taken to restrict

application of the item to siding other than with expanded plastic or rubber backing or

1 Docket 2003-4, Subject 8 (November, 2003)


SUBJECT 14


insulation, along with the establishment of the Note, item 1705832. A recent interpretation

inquiry has exposed additional descriptive issues, specifically with siding constructed wholly of

expanded plastic. While item 170580 was not intended to apply on expanded plastic siding,

under the current provisions, the entry is open to all plastic siding whether expanded or not;

the only existing restriction applies to siding that is combined with expanded plastic or rubber

backing or insulation.


CCSB policies state that the Classification should be amended as necessary to

eliminate the source, or potential source, of interpretation disputes. Item 170580 is not

intended to apply on expanded plastic siding; however, as the item is not specifically

restricted to “other than expanded” for the siding itself (sans backing or insulation), the entry is

less than clear for the Classification user.

Amending item 170580 by inserting the modifying phrase “other than expanded

plastic” would provide clarity and address the existing interpretation issue. In addition,

amending the attendant Note, item 170583, by explicitly stating that expanded plastic siding is

classified under item 157320 would promote further clarification.

As docketed, this proposal is consistent with CCSB policy regarding clarification.

2 Docket 2004-4, Subject 13 (November, 2004)


SUBJECT 15


Re: Notes, Items 132992, 133072 and 142712, and Item 142700






132920 Water Wheels and Parts, see Note, item 132992:

132992 NOTE—When in shipments of 24,000 pounds or more, provisions also apply

when in mixture with equipment of steel foundation beams or bridge

trees.

133070 Well Boring or Drilling Machines, portable or self-propelled, see Note, item

133072 ............................................................................................. Not Involved

133072 NOTE—When in shipments of 24,000 pounds or more, provisions also apply on

equipment of parts or tools, or rig irons, boilers, engines, crown blocks,

draw works, derricks, ladders, mud mixers, pumps or well casing.

142700 OIL, WATER, GAS WELL GROUP: Articles consist of Oil, Water, or Gas Well

Outfits or Supplies, see Note, item 142712, as described in items

subject to this grouping.

142712 NOTE—The following equipment or appliances, forming a part of oil, water or

gas well outfits or supplies, will, if shipped in mixtures with such oil, water or

gas well outfits or supplies of 36,000 pounds or more, be taken at class

applicable on such oil, water or gas well outfits or supplies:

Air compressors; anvils; belts; blacksmith’s rotary blowers; boilers, including

fire brick and fire clay for setting; boiler parts, boiler fronts and grate

bars; electric generators; engines; pipe or pipe fittings; power

pumps; pull rods; reducers, gear or speed; rope; smokestacks; sucker

rods; tanks, oil and gas separating, automatic; working barrels

(pump cylinders); steam boiler trucks or running gears, KD; one box

mechanics’ tools, second-hand (used), not exceeding 1,000 pounds

in weight.




132920 Water Wheels and Parts:


133070 Well Boring or Drilling Machines, portable or self-propelled .............. No Change


142700 OIL, WATER OR GAS WELL GROUP: Articles consist of Oil, Water or Gas Well

Supplies, as described in items subject to this grouping.



SUBJECT 15


Analysis and Relationship to CCSB Policies and Guidelines

The provisions of Notes, items 132992, 133072 and 142712 were adopted from the rails in

1936 and have remained substantially unchanged to the present. A member carrier recently

brought these Notes to the attention of the CCSB as possibly being obsolete. A review of these

provisions reveals that they apply on mixed truckload shipments, which are unlikely to move

subject to the NMFC™. Moreover, such provisions may be misapplied, as they can be difficult

to interpret and enforce.

It is CCSB policy to promote clarification and simplification of the NMFC™, including

removal of obsolete provisions. Canceling Notes, items 132992, 133072 and 142712 as having

no further application and removing the references to these Notes from items 132920, 133070

and 142700, respectively, would be consistent with CCSB policies.

Also, a review of the provisions listed under the Oil, Water or Gas Well Group finds that

no outfits are named within the generic group. Therefore, it would also be within CCSB policy

to remove the reference to “Outfits” from the description of item 142700.

CCSB DOCKET 2013-1 SECTION II

Notice of changes to be made to provisions of the Classification pursuant to Rule 10 of the

Rules of Procedure for Amending the Provisions of the National Motor Freight ClassificationTM.

Changes will be published in a future supplement to, or issue of, the Classification.

CHANGES TO THE CLASSIFICATION MADE NECESSARY BY LAW,

BY ORDER OF A REGULATORY BODY OR FOR CLARIFICATION

©2012 National Motor Freight Traffic Association, Inc. Section II, Page 1 of 1

[NO CHANGES AT THIS TIME]


NOTES



NOTES



NOTES


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