CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Re: Film or Sheeting, plastic or rubber, other than rigid
CCSB Contact: Erin N. Topper
Telephone — (703) 838-8856
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
Description
Class
PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item
156500
156600
Articles, viz.:
Articles, NOI;
[Other Articles Listed—Not Involved.]
In boxes, crates, drums or Packages 870, 1078, 1241, 1273, 1456,
2195, 2212, 2213, 2230 or 2459, see Note, item 156602,
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
156602
NOTE—The following departures from packing requirements are permitted:
1-10. Not Involved.
11. Plastic or rubber film or sheeting may be shipped in wrapped
bundles or rolls, or Packages 591, 2057, 2058, 2059, 2103 or 2221.
12-20. Not Involved.
156603
NOTE—Not Involved.
156604
NOTE—Not Involved.
156830
Film or Sheeting, NOI, see Note, item 156833, in boxes, crates, wrapped
bundles or rolls, or Packages 591, 2057, 2058, 2059, 2103 or 2221,
having a density of 35 pounds or greater per cubic foot, see Note,
item 156835.................................................................................................... 55
156833
NOTE—Does not apply on self-supporting (rigid) plastic sheet or plate. For
applicable provisions, see item 156300.
156835
NOTE—Density must be shown by shipper on shipping orders and bills of lading
at time of shipment. If density is not shown and shipment is inadvertently
accepted, class will initially be assessed under the provisions of item
156600, naming 'Plastic or Rubber Articles, NOI.' Upon satisfactory proof of
actual density, class will be adjusted accordingly.
©2015 National Motor Freight Traffic Association, Inc.
Subject 5, Page 1 of 9
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Proposed Classification Provisions
Item
156600
156602
156603
156604
156830
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
A-NEW
B-NEW
156833
C-NEW
Description
Class
PLASTIC OR RUBBER ARTICLES, OTHER THAN EXPANDED, GROUP: subject to item
156500
Articles, viz.:
Articles, NOI;
[Other Articles Listed—No Change.]
In boxes, crates, drums or Packages 870, 1078, 1241, 1273,
1456, 2195, 2212, 2213, 2230 or 2459, see Note, item
156602, etc ........................................................................... No Change
NOTE—The following departures from packing requirements are permitted:
1-10. No Change.
11. Not currently used.
12-20. No Change.
NOTE—No Change.
NOTE—No Change.
Film or Sheeting, NOI, see Note, item A-NEW, in boxes, crates, wrapped
bundles or rolls, or Packages 591, 2057, 2058, 2059, 2103 or 2221, see
Note, item B-NEW:
Food or pharmaceutical grade, see Note, item C-NEW, subject to
Item 170 and having a density in pounds per cubic foot of:
Less than 15 ................................................................................................. 110
15 but less than 30 ........................................................................................ 77.5
30 or greater .................................................................................................. 65
Other than food or pharmaceutical grade as defined in Note, item
C-NEW, subject to Item 170 and having a density in pounds
per cubic foot of:
Less than 15 ................................................................................................. 100
15 but less than 30 ........................................................................................ 70
30 or greater .................................................................................................. 60
NOTE—Does not apply on self-supporting (rigid) plastic sheet or plate. For
applicable provisions, see item 156300.
NOTE—Film or sheeting tendered for shipment on lift truck skids or pallets must
not overhang the skid or pallet deck, and all exposed surfaces and edges
must be completely wrapped with plastic film or corrugated fiberboard.
Film or sheeting stacked on lift truck skids or pallets must be secured to the
lift truck skid or pallet by means necessary to withstand the normal rigors
of the less-than-truckload environment.
NOTE—Cancel; see item A-NEW.
NOTE—The term ‘food or pharmaceutical grade' embraces film or sheeting
that will be used in connection with food, foodstuffs, pharmaceuticals or
other applications, and where exposure of the film or sheeting to
hazardous materials, odor-emitting freight, debris or other contaminants
will result in a claim for, or refusal of, all or part of the shipment. Bills of
lading and shipping orders must be so notated, and shipping containers
or packages must also be so marked.
Subject 5, Page 2 of 9
©2015 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Proposed Classification Provisions — Concluded
Item
156835
Description
Class
NOTE—Cancel; no further application.
Analysis
Research Project 1216
Research Project 1216 was initiated in February 2014 on plastic or rubber film or
sheeting, other than rigid, as classified in items 156600 and 1568301, in response to reports of
handling units not meeting the density-floor restriction of 35 pcf in item 156830 nevertheless
being classified in that item. In addition, multiple sources identified claims issues resulting from
food or pharmaceutical grade plastic film or sheeting being coloaded with specific products,
e.g., hazardous materials and odor-emitting freight.
In conjunction with the project, questionnaires were mailed to 449 potential
manufacturers or shippers of the involved products and six associations believed to represent
those manufacturers or shippers in March 2014, and for those that did not respond, again in
May 2014. From those mailings, usable information was received from 11 companies; nine
companies responded, but did not provide usable data; and 12 companies reported that
they do not manufacture or ship these products. In June 2014, one major manufacturer of the
involved products contacted the CCSB in response to the commodity questionnaire. The
shipper indicated a willingness to provide detailed shipment information and was emailed a
spreadsheet to facilitate the submission of the data. However, no response was received from
the shipper, even when contacted a second time in October 2014. No responses were
received from any of the associations.
History of Provisions
Provisions for plastic film or sheeting were adopted from the rails in 1936 as cellulose film.
Over the years, the provisions have been amended, but the most recent changes occurred as
a result of action taken on Docket 2005-1, Subject 8 (February 2005). The current class 55 in
item 156830 was assigned to apply on plastic film or sheeting having a density of 35 pcf or
greater. Concurrently, two attendant Notes were established, one restricting item 156830 from
applying on self-supporting (rigid) plastic sheet or plate, and the other providing an
inadvertence clause in the event the density is not shown at time of shipment. A new
paragraph (11) was added to Note, item 156602 to allow for the currently applicable
packaging requirements for film or sheeting not meeting the density-floor restriction of 35 pcf
in item 156830 and, thus, classified in item 156600. The provisions first appeared in Supplement
2 to NMF 100-AE, effective April 30, 2005, and have remained unchanged to the present.
While rubber film or sheeting is classified in these items, most of the involved film or sheeting is plastic.
As such, the material will be referred to herein as “plastic film or sheeting.”
1
©2015 National Motor Freight Traffic Association, Inc.
Subject 5, Page 3 of 9
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
About Plastic Film or Sheeting
Plastic film or sheeting is made of various polymers, such as low density
and high density polyethylene (LDPE and HDPE) and polypropylene (PP),
which are melted and extruded into a thin, flexible material that is used in a
variety of applications. Plastic film or sheeting may be manufactured in
sheets or rolls and is often used for food or pharmaceutical packaging, such
as the bag of vegetables shown on the left.
Shipments of Plastic Film or Sheeting
Rolls of plastic film or sheeting may be wrapped around cores, secured in or on cradles,
or enclosed in fiberboard boxes. Sheets of plastic film or sheeting may be tendered in
fiberboard boxes or simply stacked on lift truck skids or pallets. As shown in the example
shipments below, plastic film or sheeting is generally tendered on lift truck skids or pallets and
secured using strapping and/or plastic film.
Subject 5, Page 4 of 9
©2015 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Transportation Characteristics
Density—The information of record includes 101,738 density observations submitted by shippers
and carriers, observed firsthand on CCSB dock surveys and gathered from the CCSB’s Density
Study2. The densities range from 0.65 to 149.82 pcf, with an average of 23.49 pcf. The data
can be divided into three density groupings of less than 15 pcf, 15 but less than 30 pcf, and 30
pcf or greater.
% of Figures in Interval
Frequency Distribution
50.00%
40.37%
40.00%
27.02%
30.00%
14.77%
20.00%
10.00%
6.79%
3.42% 4.32%
0.01% 0.03% 0.36% 0.83% 2.08%
0.00%
Density Intervals (pcf)
When the data of record is evaluated on the basis of the three proposed density
groupings, the following ranges and averages are calculated.
Density Group (pcf)
Less than 15
15 but less than 30
30 or greater
Density Range (pcf)
0.65 – 14.99
15.00 – 29.99
30.00 – 149.82
Average Density (pcf)
10.70
23.63
38.31
It should be noted that item 156830 is currently assigned class 55 and requires a
minimum density of 35 pcf. However, the information of record for densities reported under this
item indicates a range from 0.75 to 149.82 pcf, with an average of 23.90 pcf. The average
density of 23.90 pcf, which is generally associated with a class 65 based on CCSB density
guidelines, is an indication that this item is not being correctly applied.
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
©2015 National Motor Freight Traffic Association, Inc.
Subject 5, Page 5 of 9
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Handling—As shown in the photos on page 4 of this analysis, plastic film or sheeting is generally
tendered on lift truck skids or pallets, which permits mechanical handling. Some units are
marked “Fragile” and/or “Handle with Care,” indicating that some degree of care and
attention is required when handling these products. If the film or sheeting is not properly
secured to the lift truck skid or pallet, handling issues may be present.
Food or pharmaceutical grade plastic film or sheeting presents additional handling
considerations as it must be kept clean from debris and free from contamination, or even the
perception of contamination, at carrier facilities and while in transit.
Stowability—Plastic film or sheeting tendered in boxes or in rolls stacked on lift truck skids or
pallets may provide a flat load-bearing surface for compatible top freight. However, many
handling units are labeled “Do Not Stack” or “Do Not Double Stack or Stack Heavy Freight on
Top,” even when a flat load-bearing surface is present, limiting the carrier’s ability to structure
a load and maximize vehicle utilization.
Food or pharmaceutical grade plastic film or sheeting will often require segregation
from potential contaminants, such as hazardous materials, odor-emitting freight, or debris.
Depending on the carrier’s freight mix, these coloading restrictions or prohibitions may result in
the need to dispatch additional vehicles for the shipment of these materials, which is not
necessary for general freight.
Liability—Plastic film or sheeting does not have the propensity to
damage other freight, nor is it unusually susceptible to theft. However,
plastic film or sheeting not adequately protected by packaging, or not
properly secured to lift truck skids or pallets, may be liable to damage
from the normal rigors of the LTL environment. The photo on the left
demonstrates how rolls may shift on a lift truck skid or pallet when
stacked on end and not securely fastened to the lift truck skid or pallet.
With regards to claims, shippers report zero to 12 claims annually. The value per pound ranges
from $0.14 to $20.83, with an average of $2.58 per pound.
Food or pharmaceutical grade plastic film or sheeting requires additional protection
from freight with which stowed, such as hazardous materials and odor-emitting freight, as well
as from debris. The labels and bill of lading notation shown on the following page are from
actual shipments of these products, which indicate a significantly greater liability risk. At least
one carrier has reported entering into a contractual agreement with a shipper of these
products, which provides specific requirements as to how the freight must be handled and
stowed in order to reduce the chance of damage or claims. Other carriers have reported
refused shipments and resulting claims for plastic film or sheeting that has been coloaded or
has come in contact with potential contaminants, including instances where the carrier had
not been informed in advance of the need to take extraordinary protective measures in
handling or stowing the freight.
Subject 5, Page 6 of 9
©2015 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Relationship to CCSB Policies and Guidelines
Plastic film or sheeting is currently classified in item 156830 provided the density floor of
35 pcf is met. When handling units have a density of less than 35 pcf, item 156600 is to be
applied. Information of record indicates, however, that item 156830 is being routinely applied
to plastic film or sheeting regardless of density. This proposal would amend item 156830 to
apply to all of the involved plastic film or sheeting. Concurrently, the packaging exceptions
for the involved products provided in paragraph 11 of Note, item 156602, which is subordinate
to item 156600, would be removed as having no further application.
CCSB policies call for establishing or amending classification provisions to reflect a
commodity’s known transportation characteristics. Information of record for plastic film or
sheeting includes 101,738 density observations, ranging from 0.65 to 149.82 pcf, with an
average of 23.49 pcf. Under CCSB guidelines, an average density of 23.49 pcf is generally
associated with class 65, which calls for a minimum average density of 22.5 pcf. However,
when commodities exhibit a wide range of densities, which are not accurately represented by
a single class, CCSB policies state that density-based provisions may be established. When the
data of record is evaluated based on the proposed density breaks at 15 and 30 pcf, the
average densities and classes shown in the table below emerge.
Density Group (pcf)
Average Density (pcf)
Less than 15
15 but less than 30
30 or greater
10.70
23.63
38.31
CCSB Minimum
Average Density
Guideline (pcf)
10.5
22.5
35
©2015 National Motor Freight Traffic Association, Inc.
Class Based on
CCSB Density
Guidelines
92.5
65
55
Subject 5, Page 7 of 9
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
As shown in the photos herein, plastic film or sheeting may be shipped in rolls or in
sheets, boxed or not boxed, typically secured on lift truck skids or pallets. Generally, the freight
should be readily handled with mechanical equipment, but as evidenced by shipper
instructions and precautionary markings, some degree of care and attention is required when
handling these products. Moreover, there may be handling issues if the film or sheeting is not
properly secured to the lift truck skid or pallet. When stowing, plastic film or sheeting may not
be double-stacked or top-loaded due to the configuration of the handling unit, or due to
shipper instructions or precautionary markings. Plastic film or sheeting not adequately
protected by packaging, or not properly secured to lift truck skids or pallets, may be liable to
damage from the normal rigors of the LTL environment.
In addition to the negative handling, stowing and liability considerations noted above,
food or pharmaceutical grade plastic film or sheeting poses additional risks, because it must
not be coloaded with a number of products, such as hazardous materials or odor-emitting
freight, and must be kept free from debris. These requirements present additional operational
concerns for carriers, including the need to dispatch a separate vehicle to move the freight.
In this regard, carriers have reported refused shipments and resulting claims for plastic film or
sheeting that has been coloaded or has come in contact with potential contaminants.
Therefore, it would be in keeping with CCSB policies and precedent to amend item
156830 by establishing classes based on whether or not the plastic film or sheeting is food or
pharmaceutical grade, and on density3. Plastic film or sheeting, other than food or
pharmaceutical grade would be assigned one class higher than that called for by the
average density of each density group due to the significant handling, stowability and liability
considerations. Food or pharmaceutical grade plastic film or sheeting would be assigned two
classes higher than that called for by the average density, as there are additional handling
and stowability requirements and restrictions, and the carriers’ liability is greatly increased due
to the risk of “special damages” associated with this type of plastic film or sheeting. The table
below details the proposed classes.
Density Group (pcf)
Average
Density
(pcf)
Class Based
on CCSB
Density
Guidelines
Less than 15
15 but less than 30
30 or greater
10.70
23.63
38.31
92.5
65
55
One-Class
Adjustment Based on
Handling, Stowability
and Liability
Considerations
100
70
60
Two-Class
Adjustment Based on
Handling, Stowability
and Liability
Considerations
110
77.5
65
Note, item 156833 would be canceled and reestablished. Note, item 156835 would be
canceled as having no further application.
3
The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
Subject 5, Page 8 of 9
©2015 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-1
SECTION I
SUBJECT 5
Furthermore, it is proposed to add two new Notes. The first Note would provide
additional packaging requirements for plastic film or sheeting. The second Note would
provide a definition of food or pharmaceutical grade plastic film or sheeting and would
require shippers to give notice of the special nature of this freight to the carrier at time of
shipment.
With respect to commodities that exhibit less-than-favorable handling, stowability or
liability characteristics, classification precedent has been to assign classes higher than what
would generally be called for under the density guidelines. An example of such an approach
can be found in Docket 2012-3, Subject 7 (September 2012) involving fiber optic cable, as
named in item 57770. In that instance, the CCSB approved provisions for cable based on
whether or not cut to specified length, and on density; wherein fiber optic cable not cut to
specified length was assigned one class higher than that called for under CCSB density
guidelines, while fiber optic cable cut to specified length was assigned two classes higher than
that called for under CCSB density guidelines, in view of their respective negative handling,
stowing and liability characteristics. The provisions first appeared in Supplement 4 to NMF 100AL, effective December 1, 2012.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policies and precedent.
©2015 National Motor Freight Traffic Association, Inc.
Subject 5, Page 9 of 9