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.
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