CCSB DOCKET 2011-1
SECTION I
SUBJECT 4
Re: Electrical Appliances or Instruments, NOI
Staff Contact: William F. Mascaro
Telephone — (703) 838-1834
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
61700
61701
Description
Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
Electrical Appliances or Instruments, NOI, see Note, item 61701, in boxes,
crates or Packages 829, 1241 or 2112 ..................................................... 100
NOTE—Not Involved.
Proposed Classification Provisions
Item
Description
Class
ELECTRICAL EQUIPMENT GROUP: subject to item 60500
61700
Electrical Appliances or Instruments, NOI, see Note, item 61701, in boxes,
crates or Packages 829, 1241 or 2112, 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
61701
NOTE—No Change.
Analysis
This proposal is based on information developed through Research Project 1113, which
was initiated by the CCSB to review the transportation characteristics of electrical appliances
or instruments moving under the provisions of item 61700, “Electrical Appliances or Instruments,
NOI.”
The provisions of item 61700 were adopted from the rail classification in 1936 at a rating
equivalent to the currently applicable class 100 and have remained substantially unchanged
since that time.
©2010 National Motor Freight Traffic Association, Inc.
Subject 4, Page 1 of 4
CCSB DOCKET 2011-1
SECTION I
SUBJECT 4
Item 61700 is the general or catchall provision for the Electrical Equipment Group. As
such, it applies on a multitude of different electrical articles not named elsewhere in the
NMFC. Given the breadth of different commodities that may be subject to the provisions of
item 61700, notice of this proposal has been sent to 41 trade associations that may represent
shippers or other interested parties of electrical appliances or instruments.
Transportation Characteristics
Density: The information of record encompasses 30,512 density observations and
indicates a range from 1.00 to 50.00 pcf, with a simple average density of 9.58 pcf. A
frequency distribution of the overall density range is shown below.
Frequency Distribution
24.76
25.00
% of Figures in Interval
20.63
20.00
15.97
15.00
11.41
11.37
10.00
10.00
5.00
0.00
0.82
2.06
1.81
1.15
0.00
Less
than 1
1 but 2 but 4 but 6 but
less
less
less
less
than 2 than 4 than 6 than 8
8 but
less
than
10
10 but 12 but 15 but
less
less
less
than
than
than
12
15
22.5
22.5 30 or
but greater
less
than
30
Density Intervals (pcf)
As depicted in the graph, the density figures are distributed throughout the range with
no clear breaks or gaps within the range. Also, while the density observations are distributed
throughout the range, the greatest concentrations of figures are in the 4 but less than 6 pcf
and 6 but less than 8 pcf groupings, and approximately 56% of the density observations are
less than 9 pcf. This indicates that the overall average density of 9.58 pcf is not reflective of
the density range. 4.76% of the density observations are greater than 20 pcf.
Handling: Electrical appliances or instruments are generally tendered for shipment in
fiberboard boxes that may be palletized for shipment. Handling would be comparable to
other like packaged freight.
Subject 4, Page 2 of 4
©2010 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2011-1
SECTION I
SUBJECT 4
Stowability: There is no indication of any unusual or significant stowing considerations.
Liability: There is no evidence that the factors which comprise the liability transportation
characteristic would present any unusual or significant liability considerations. While liability
has long been a concern of motor carriers with respect to certain electrical or electronic
goods, a survey of motor carrier claims professionals did not reveal any indication of a claims
problem in connection with item 61700.
Relationship to CCSB Policies and Guidelines
CCSB policy calls for classification provisions to reflect a commodity’s known
transportation characteristics. Information of record indicates that commodities reported to
be moving under the provisions of item 61700 range in density from 1.00 to 50.00 pcf, with a
simple average density of 9.58 pcf. CCSB guidelines for the currently applicable class 100 call
for a minimum average density of 9 pcf.
CCSB policy further provides that commodities or commodity groups 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
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, full-scale density
classifications should generally provide the alternative standard progression that ranges from
class 400 assigned to articles with densities less than 1 pcf to class 60 assigned to articles with
densities 30 pcf or greater.
While the reported average density of 9.58 pcf is consistent with CCSB guidelines for the
currently applicable class 100, the density range is quite wide, from 1.00 to 50.00 pcf, and the
majority of the figures, approximately 56%, are less than 9 pcf. Also, as stated in the density
discussion, the greatest concentrations of figures are in the 4 but less than 6 pcf and 6 but less
than 8 pcf groupings, and 4.76% of the density observations are greater than 20 pcf. This
indicates that the average density is not reflective of the overall density range and that
extended full-scale density-based provisions would reflect the densities of electrical
appliances or instruments moving under item 61700 and be in keeping with CCSB policy.
Such an approach would also be in keeping with CCSB precedent. Since 2000, when
the classification policies with respect to full-scale density-based provisions were changed to
include the policy regarding the extended density scale, multiple items in the NMFC have
been amended or established to provide that extended scale. A recent example may be
found in CCSB Docket 2010-2, Subject 2 (June 2010), which was a proposal to establish the
CCSB’s extended density scale for dry goods as named in item 49390, in lieu of the thenassigned class 100. Information from the record indicated densities ranging from 1.00 to 47.84
pcf, with a simple average density of 8.89 pcf. The record further showed that 62% of the
figures were in the 4 but less than 10 pcf range, and that 4% of the figures exceeded 20 pcf.
©2010 National Motor Freight Traffic Association, Inc.
Subject 4, Page 3 of 4
CCSB DOCKET 2011-1
SECTION I
SUBJECT 4
The proposed density-based classes are also consistent with precedent established by
the US DOT’s 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.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
Subject 4, Page 4 of 4
©2010 National Motor Freight Traffic Association, Inc.