CCSB DOCKET 2012-3
SECTION I
SUBJECT 12
Re: Barracks or Duffel Bags — Item 20600
Staff Contact: Allison L. Austin
Telephone — (703) 838-8864
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
Description
Class
20500
20502
BAGS: see Note, item 20502
NOTE—Will only apply on bags other than traveling or carrying bags or cases,
briefcases, portfolios or envelope-type carrying pouches.
20600
Barracks or Duffel, in bales or boxes:
Sub 1
Cotton .................................................................................................................. 85
Sub 2
NOI ...................................................................................................................... 100
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©2012 National Motor Freight Traffic Association, Inc.
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Present Classification Provisions — Concluded
Item
187645
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
Sub 9
187682
Description
Class
TRUNKS, TRAVELING BAGS OR RELATED ARTICLES: subject to item 187600
Carrying Cases or Bags, viz.:
Air Transport of America (ATA) Cases;
Archery Bow Cases;
Audio (Sound) Recording Carrying Cases;
Backpack Baby Carriers;
Backpacks;
Bowling Ball or Bowling Shoe Bags or Cases;
Boxes or Bags, lunch or picnic, NOI, with or without food or beverage
containers;
Camera, Camera Equipment or Film Projector Carrying Bags, Cases or
Pouches;
Carrying Cases or Bags, NOI;
Footlockers;
Gun Carrying Cases;
Handbags;
Hatboxes;
Haversacks;
Knapsacks;
Luggage, NOI;
Musical Instrument Cases, NOI;
Pack Carriers, NOI;
Pocketbooks or Purses;
Sample Cases;
Suitcases;
Traveling Bags;
Trunks;
In boxes, crates or Packages 826 or 2213, see Note, item 187682,
subject to Items 170 and 171 and having a density in pounds
per cubic foot of:
Less than 1 ............................................................................................. 400
1 but less than 2 .................................................................................... 300
2 but less than 4 .................................................................................... 250
4 but less than 6 .................................................................................... 150
6 but less than 8 .................................................................................... 125
8 but less than 10 .................................................................................. 100
10 but less than 12 .................................................................................. 92.5
12 but less than 15 .................................................................................. 85
15 or greater ............................................................................................ 70
NOTE—Not Involved.
Subject 12, Page 2 of 6
©2012 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2012-3
SECTION I
SUBJECT 12
Proposed Classification Provisions
Item
20502
20600
187645
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
Sub 9
187682
Description
Class
BAGS: subject to item 20500
NOTE—No Change.
Barracks or Duffel, etc. ........................................................................... Cancel; see
item 187645
TRUNKS, TRAVELING BAGS OR RELATED ARTICLES: subject to item 187600
Carrying Cases or Bags, viz.:
Duffel or Barracks Bags;
[Other Articles Listed — No Change.]
In boxes, crates or Packages 826 or 2213, see Note, item 187682,
subject to Items 170 and 171 and having a density in pounds
per cubic foot of:
Less than 1 ............................................................................................. 400
1 but less than 2 .................................................................................... 300
2 but less than 4 .................................................................................... 250
4 but less than 6 .................................................................................... 150
6 but less than 8 .................................................................................... 125
8 but less than 10 .................................................................................. 100
10 but less than 12 .................................................................................. 92.5
12 but less than 15 .................................................................................. 85
15 or greater ............................................................................................ 70
NOTE—No Change.
Analysis
Research Project 1146
This proposal is based on information developed through Research Project 1146, which
was initiated by the CCSB in December 2011 in response to interpretation questions regarding
the proper classification for duffel bags. These commodities are named in item 20600.
However, interpretation issues have arisen from confusion about whether products marketed
as duffel bags meet the requirements of the item, as Note, item 20502 restricts application to
non-traveling or non-carrying bags. Despite the discrepancy, in opinions item 20600 has been
held to be more specific than the general provisions of item 187645 for carrying cases or bags.
During the course of Research Project 1146, 249 potential manufacturers or shippers of
duffel bags and four associations believed to represent those companies, were sent
commodity questionnaires in December of 2011, and for those that did not respond, again in
February of 2012. Of the companies contacted, 15 responded that they do not manufacture
or ship duffel bags, two questionnaires were returned as undeliverable, and 14 companies
provided information; however, not all the information was usable. No responses were
received from the associations contacted. Additional information of record for this proposal
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was developed through CCSB dock surveys, carrier-submitted Shipment Information Forms and
the CCSB‟s Density Study1.
History of Provisions
Provisions for barrack bags were adopted from the rail classification in 1936. The term
“duffel” was added to the item description as a result of action taken on Subject 3 of Docket
67 (January 1955) and first appeared in Supplement 10 to NMFC A-2, effective May 24, 1955.
The current provisions are a result of action taken on Subject 1 of Docket 797 (October 1979)
and first appeared in Supplement 7 to NMF 100-G, effective August 16, 1980. That was a
shipper proposal which sought to amend the class and was approved as modified, resulting in
two subprovisions, based on material construction. The provisions have remained substantially
unchanged to the present.
About Duffel Bags
Products represented as duffel bags have evolved since the original provisions were
adopted from the rails. Traditionally, duffel bags and barracks bags were synonymous and
related to bags of a cylindrical cloth construction with a drawstring closure and utilized
primarily by soldiers in the transport of personal belongings2. As evident from the photos below
and on the following page, today, duffel bags also encompass a range of commercial
products. They are constructed from a variety of materials, including polyester, leather and
nylon and come in many different styles including wheeled, upright and expandable. These
duffel bags are also often included in multi-piece luggage sets.
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 http://olive-drab.com/od_soldiers_gear_barracks_bag.php(accessed May 25, 2012)
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©2012 National Motor Freight Traffic Association, Inc.
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Transportation Characteristics
Density—Information of record for duffel bags includes 366 density observations. The products
range in density from 1.79 to 39.18 pcf, with a simple average density of 7.47 pcf. A frequency
distribution is shown below.
Frequency Distribution
% of Figures in Interval
35.00%
31.42%
30.00%
25.00%
19.13%
20.00%
15.00%
9.84%
10.00%
5.00%
16.39%
7.65% 6.83% 6.56%
1.37% 0.27%
0.00% 0.55%
0.00%
Density Intervals (pcf)
As the above frequency distribution depicts, the figures are distributed throughout the
range, although almost 67% of the figures are between 2 and 8 pcf, and only 2.19% of the
figures exceed 20 pcf.
Handling—Duffel bags are generally packaged in fiberboard boxes and may or may not be
palletized for shipment. No significant handling issues have been identified.
Stowability—No significant stowability concerns have been reported.
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Liability—There is no indication of any unusual liability considerations. Duffel bags are not
perishable, prone to spontaneous combustion or explosion, unusually susceptible to theft,
unusually liable to damage or likely to damage other freight. Limited value information reveals
a value per pound range from $2.15 to $127.78, with a simple average value of $21.39 per
pound. No carrier claims have been reported, and responding shippers have indicated
minimal to no claims on these commodities.
Relationship to CCSB Policies and Guidelines
CCSB policy calls for amending classification provisions that are a source, or potential
source, of interpretation disputes so as to eliminate or avoid those disputes. Interpretation
questions have arisen as to the applicable provisions for duffel bags. CCSB opinions have held
item 20600 applicable for duffel bags, despite the inconsistencies with the Note, item 20502
precluding application on traveling or carrying bags. Duffel bags are commodities that
function to carry clothing and other personal belongings, similar to products embraced under
item 187645 for carrying bags or cases. These interpretation disputes could be mitigated by
combining these related commodities.
CCSB policy also calls for provisions to reflect a commodity‟s known transportation
characteristics. Information of record indicates that duffel bags range in density from 1.79 to
39.18 pcf, with an average density of 7.47 pcf. This average density is inconsistent with the
currently assigned classes 85 and 100, which under CCSB guidelines call for minimum average
densities of 12 pcf and 9 pcf, respectively, and the majority of figures are between 2 and 8
pcf. Additionally, as shown on page 5, the figures are widely distributed throughout the range
(though only 2.19% of the figures exceed 20 pcf). CCSB policy provides that commodities
exhibiting a wide density range, especially where there are no unusual or significant handling,
stowing or liability characteristics, may be assigned density-based classes.
Canceling item 20600 with reference to the full-scale density-based provisions of item
187645 and concurrently amending the description of item 187645 to specifically name „duffel
or barracks bags‟ would address the interpretation issues, while providing classes reflective of
the current transportation characteristics3.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy.
Item 187645 provides the CCSB‟s standard nine-subprovision density scale, which includes reference to
Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the “bumping” privilege.
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©2012 National Motor Freight Traffic Association, Inc.