Post on 15-Aug-2018
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
©2012 National Motor Freight Traffic Association, Inc.
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
ccsb@nmfta.org 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
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
©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.
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
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
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
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
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
©2012 National Motor Freight Traffic Association, Inc.
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 ripke@nmfta.org
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 2 of 10
Present Classification Provisions — Concluded
Item Description Class
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 3 of 10
Proposed Classification Provisions
Item Description Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
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
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—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
having a density in pounds per cubic foot of:
Subs 1-11 No Change.
116031 NOTE—No Change.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 4 of 10
Proposed Classification Provisions — Concluded
Item Description Class
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 5 of 10
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 6 of 10
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 7 of 10
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 8 of 10
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 9 of 10
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 1
©2012 National Motor Freight Traffic Association, Inc. Subject 1, Page 10 of 10
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 1 of 6
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 horning@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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.
THIS SPACE INTENTIONALLY LEFT BLANK
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 2 of 6
Proposed Classification Provisions
Item Description Class
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
56791 NOTE—No Change.
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.
Research Project 1154
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 3 of 6
Additional information was developed through the CCSB Density Study1, CCSB dock
surveys and carrier-submitted reports.
History of Provisions
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 4 of 6
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.
Transportation Characteristics
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
Density Intervals (pcf)
Frequency Distribution
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 5 of 6
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.
Relationship to CCSB Policies and Guidelines
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 2
©2012 National Motor Freight Traffic Association, Inc. Subject 2, Page 6 of 6
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.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 3
©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 1 of 7
Re: Hand Tools, other than power
Staff Contact: William F. Mascaro Telephone — (703) 838-1834 mascaro@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 3
©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 2 of 7
Present Classification Provisions — Continued
Item Description Class
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;
CCSB DOCKET 2013-1 SECTION I
SUBJECT 3
©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 3 of 7
Present Classification Provisions — Concluded
Item Description Class
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.
Proposed Classification Provisions
Item Description Class
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.
CCSB DOCKET 2013-1 SECTION I
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©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 4 of 7
Analysis
Research Project 1134
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.
History of Provisions
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 3
©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 5 of 7
Hand Tools
Transportation Characteristics
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.
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 NMFCTM item, and only verifiable data
points, which include the weight and the dimensions and/or cube of the shipping unit involved, are
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
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©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 6 of 7
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.
Relationship to CCSB Policies and Guidelines
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
CCSB DOCKET 2013-1 SECTION I
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©2012 National Motor Freight Traffic Association, Inc. Subject 3, Page 7 of 7
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 4
©2012 National Motor Freight Traffic Association, Inc. Subject 4, Page 1 of 5
Re: Burners, Sprayers or Vaporizers, boiler, furnace or commercial or industrial baking oven
Staff Contact: William F. Mascaro Telephone — (703) 838-1834 mascaro@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
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
Proposed Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
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
having a density in pounds per cubic foot of:
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
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 4
©2012 National Motor Freight Traffic Association, Inc. Subject 4, Page 2 of 5
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.
History of Provisions
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 4
©2012 National Motor Freight Traffic Association, Inc. Subject 4, Page 3 of 5
Transportation Characteristics
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
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 NMFCTM item, and only verifiable data
points, which include the weight and the dimensions and/or cube of the shipping unit involved, are
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 4
©2012 National Motor Freight Traffic Association, Inc. Subject 4, Page 4 of 5
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 4
©2012 National Motor Freight Traffic Association, Inc. Subject 4, Page 5 of 5
Relationship to CCSB Policies and Guidelines
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 1 of 7
Re: Washers (Washing Machines) or Washer-extractors, laundry, other than household
Staff Contact: Donald A. Newell Telephone — (703) 838-1890 newell@nmfta.org
Allison L. Austin (703) 838-8864 austin@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
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
Proposed Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
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
Research Project 1110
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 2 of 7
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.
History of Provisions
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.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 3 of 7
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 4 of 7
Transportation Characteristics
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 5 of 7
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.
Relationship to CCSB Policies and Guidelines
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 6 of 7
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 5
©2012 National Motor Freight Traffic Association, Inc. Subject 5, Page 7 of 7
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.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 1 of 8
Re: Doors or Door Sections or Grilles, garage or commercial or industrial building
Staff Contact: Nathan D. Ripke Telephone — (703) 838-1869 ripke@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 2 of 8
Proposed Classification Provisions
Item Description Class
BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item 33570
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
34282 NOTE—No Change.
34310 Doors, farm, garage, industrial or utility building, overhead,
iron or steel, without covering or skin, etc ................................ Cancel; see
item A-NEW
34311 NOTE—Cancel; no further application.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 3 of 8
Analysis
Research Project 1163
Research Project 1163 on doors or door sections, garage or commercial or industrial
building, overhead, sliding, rolling or curtain type was initiated in May 2012 to review the five
items within the Classification that apply on these commodities and to determine their
transportation characteristics. Hereinafter, these products will be referred to as ―doors, door
sections or grilles.‖
A total of 156 potential manufacturers or shippers of doors, door sections or grilles, and
six associations believed to represent those companies, were sent questionnaires in June and
August of 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.
History of Provisions
The current provisions for the involved doors, door sections or grilles are found in five
different items, which are based on material consist and/or type.
The current provisions of item 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
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 4 of 8
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 5 of 8
Transportation Characteristics
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 6 of 8
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 7 of 8
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.
Relationship to CCSB Policies and Guidelines
CCSB policies state that classifications should reflect a commodity’s known
transportation characteristics. The information of record includes 269 density observations,
which range from 1.12 to 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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 6
©2012 National Motor Freight Traffic Association, Inc. Subject 6, Page 8 of 8
class 110 generally associated with an average density of 8.44 pcf. When handling units do
not exceed 96 inches in greatest dimension, no significant handling, stowing or liability
concerns have been identified, making density the primary transportation characteristic.
Under CCSB guidelines, an average density of 7.40 pcf is associated with the proposed class
125.
CCSB policy regarding clarification, simplification and uniformity calls, in part, for
combining item descriptions embracing related commodities, structuring item descriptions so
as to foster clarification and simplification, and providing uniformity in provisions addressing the
same or similar circumstances. Therefore, it would be in keeping with CCSB policy, as
proposed, to cancel the current individual classifications for doors, door sections or grilles with
reference to a new item applying on overhead, sliding, rolling or curtain-type garage,
commercial or industrial doors, door sections or grilles, NOI, at class 125. Combining the
classifications into a single item would mitigate, if not solve, any interpretation disputes.
Furthermore, two new Notes would be added and referenced by the new item. The first
Note would clarify that the provisions also apply on accompanying hardware and fittings
when shipped in the same package. The second would provide additional packaging
requirements for the involved commodities when tendered on lift truck skids or pallets by
specifying the doors, door sections or grilles must be securely fastened to, and must not
overhang the edges of, the lift truck skid or pallet, and they must have exposed surfaces and
edges completely wrapped with plastic film or corrugated fiberboard or be protected by
wood or similar material.
This proposal is also in keeping with classification precedent. As a result of action taken
on Docket 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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 1 of 6
Re: Stone Blocks, Pieces or Slabs
Staff Contact: Erin N. Topper Telephone — (703) 838-8856 topper@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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.
90503* NOTE—Not Involved.
90504* NOTE—Not Involved.
90506* 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.
90509* NOTE—Not Involved.
*Published in Supplement 1 to NMF 100-AL, issued on March 15, 2012 with an effective date of
April 14, 2012.
Proposed Classification Provisions
Item Description Class
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 2 of 6
Proposed Classification Provisions — Concluded
Item Description Class
90502 NOTE—No Change.
90503 NOTE—No Change.
90504 NOTE—No Change.
90506 NOTE—No Change.
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.
90509 NOTE—No Change.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 3 of 6
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 4 of 6
Transportation Characteristics
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 5 of 6
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.
Relationship to CCSB Policies and Guidelines
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 7
©2012 National Motor Freight Traffic Association, Inc. Subject 7, Page 6 of 6
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 1 of 6
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 beck@nmfta.org
Proponent: Lifoam Industries, LLC, Hunt Valley, Maryland
Present Classification Provisions
Item Description Class
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
157342 NOTE—Not Involved.
157344 NOTE—Not Involved.
157346 NOTE—Not Involved.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 2 of 6
Proposed Classification Provisions
Item Description Class
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
157342 NOTE—No Change.
157344 NOTE—No Change.
157346 NOTE—No Change.
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
157461 NOTE—Cancel; no further application.
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.
History of Provisions
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 3 of 6
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:
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 4 of 6
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 5 of 6
Transportation Characteristics
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.
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.
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 8
©2012 National Motor Freight Traffic Association, Inc. Subject 8, Page 6 of 6
Relationship to CCSB Policies and Guidelines
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.
CCSB policy calls for provisions to reflect a commodity’s known transportation
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 1 of 9
Re: Waste Receptacles, steel or concrete
Staff Contact: Allison L. Austin Telephone — (703) 838-8864 austin@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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
Proposed Classification Provisions
Item Description Class
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 2 of 9
Proposed Classification Provisions — Concluded
Item Description Class
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
Research Project 1143
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 3 of 9
Additional information of record was developed through CCSB dock surveys, carrier-
submitted Shipment Information Forms and the CCSB’s Density Study1.
History of Provisions
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
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 4 of 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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 5 of 9
Concrete
Transportation Characteristics
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
Density Intervals (pcf)
Steel Waste Receptacles Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 6 of 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
Density Intervals (pcf)
Concrete Waste Receptacles Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 7 of 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.
Relationship to CCSB Policies and Guidelines
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 8 of 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.
3 The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 9
©2012 National Motor Freight Traffic Association, Inc. Subject 9, Page 9 of 9
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 10
©2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 1 of 5
Re: Partitions or Partition Doors, steel and wire combined
Staff Contact: Daniel E. Horning Telephone — (703) 838-1820 horning@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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
Proposed Classification Provisions
Item Description Class
BUILDING METALWORK GROUP: subject to item 35600
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.
Research Project 1160
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 10
©2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 2 of 5
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.
History of Provisions
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.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 10
©2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 3 of 5
Transportation Characteristics
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 10
©2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 4 of 5
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.
Relationship to CCSB Policies and Guidelines
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 10
©2012 National Motor Freight Traffic Association, Inc. Subject 10, Page 5 of 5
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 1 of 7
Re: Screen Doors or Window Screens
Staff Contact: William F. Mascaro Telephone — (703) 838-1834 mascaro@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item 33570
35310 Screens, window, adjustable, metal screen cloth in frames consisting of
metal top and bottom members (rails) and wooden ends, in boxes .. 85
BUILDING METALWORK GROUP: subject to item 35600
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.
Proposed Classification Provisions
Item Description Class
BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item 33570
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 2 of 7
Proposed Classification Provisions — Concluded
Item Description Class
BUILDING METALWORK GROUP: subject to item 35600
37080 Screen Doors or Window Screens, NOI, etc ......................................... Cancel; see
item A-NEW
37082 NOTE—Cancel; no further application.
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
38152 NOTE—Cancel; no further application.
Analysis
Research Project 1139
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.
History of Provisions
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 3 of 7
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.
Transportation Characteristics
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.
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 NMFCTM item, and only verifiable data
points, which include the weight and the dimensions and/or cube of the shipping unit involved, are
used.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 4 of 7
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
Density Intervals (pcf)
Frequency Distribution
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 5 of 7
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 6 of 7
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.
Relationship to CCSB Policies and Guidelines
CCSB policy calls for provisions to reflect a commodity’s known transportation
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
CCSB DOCKET 2013-1 SECTION I
SUBJECT 11
©2012 National Motor Freight Traffic Association, Inc. Subject 11, Page 7 of 7
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.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
2 The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 12
©2012 National Motor Freight Traffic Association, Inc. Subject 12, Page 1 of 4
Re: Electrical Switch Boxes, Conduit Outlet Boxes or Outlet Box Covers, steel, not exceeding 12
united inches—Item 61057
Staff Contact: Allison L. Austin Telephone — (703) 838-8864 austin@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
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.
THIS SPACE INTENTIONALLY LEFT BLANK
CCSB DOCKET 2013-1 SECTION I
SUBJECT 12
©2012 National Motor Freight Traffic Association, Inc. Subject 12, Page 2 of 4
Present Classification Provisions — Concluded
Item Description Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
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
63161* NOTE—Not Involved.
63162* NOTE—Not involved.
63163* NOTE—Not Involved.
*Published in Supplement 4 to NMF 100-AL, issued on November 1, 2012 with an effective date
of December 1, 2012.
Proposed Classification Provisions
Item Description Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
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
62682 NOTE—No Change.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 12
©2012 National Motor Freight Traffic Association, Inc. Subject 12, Page 3 of 4
Proposed Classification Provisions — Concluded
Item Description Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
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
63161 NOTE—No Change.
63162 NOTE—No Change.
63163 NOTE—No Change.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 12
©2012 National Motor Freight Traffic Association, Inc. Subject 12, Page 4 of 4
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.
Relationship to CCSB Policies and Guidelines
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.
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 13
©2012 National Motor Freight Traffic Association, Inc. Subject 13, Page 1 of 3
Re: Item (Rule) 110, Sec. 8, Determination of Density
Staff Contact: Donald A. Newell Telephone — (703) 838-1890 newell@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
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.
THIS SPACE INTENTIONALLY LEFT BLANK
CCSB DOCKET 2013-1 SECTION I
SUBJECT 13
©2012 National Motor Freight Traffic Association, Inc. Subject 13, Page 2 of 3
Proposed Classification Provisions
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 13
©2012 National Motor Freight Traffic Association, Inc. Subject 13, Page 3 of 3
Relationship to CCSB Policies and Guidelines
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.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 14
©2012 National Motor Freight Traffic Association, Inc. Subject 14, Page 1 of 2
Re: Siding, plastic—Item 170580
Staff Contact: Daniel E. Horning Telephone — (703) 838-1820 horning@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
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.
Proposed Classification Provisions
Item Description Class
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
170582 NOTE—No Change.
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)
CCSB DOCKET 2013-1 SECTION I
SUBJECT 14
©2012 National Motor Freight Traffic Association, Inc. Subject 14, Page 2 of 2
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.
Relationship to CCSB Policies and Guidelines
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)
CCSB DOCKET 2013-1 SECTION I
SUBJECT 15
©2012 National Motor Freight Traffic Association, Inc. Subject 15, Page 1 of 2
Re: Notes, Items 132992, 133072 and 142712, and Item 142700
Staff Contact: Allison L. Austin Telephone — (703) 838-8864 austin@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
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.
Proposed Classification Provisions
Item Description Class
MACHINERY GROUP: subject to item 114000
132920 Water Wheels and Parts:
132992 NOTE—Cancel; no further application.
133070 Well Boring or Drilling Machines, portable or self-propelled .............. No Change
133072 NOTE—Cancel; no further application.
142700 OIL, WATER OR GAS WELL GROUP: Articles consist of Oil, Water or Gas Well
Supplies, as described in items subject to this grouping.
142712 NOTE—Cancel; no further application.
CCSB DOCKET 2013-1 SECTION I
SUBJECT 15
©2012 National Motor Freight Traffic Association, Inc. Subject 15, Page 2 of 2
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]
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
NOTES
©2012 National Motor Freight Traffic Association, Inc.
COMMODITY CLASSIFICATION STANDARDS BOARD DOCKET 2013-1
NOTES
©2012 National Motor Freight Traffic Association, Inc.