CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
Re: Air Coolers or Air Conditioners, Heat Pumps, Air Handlers, or Refrigeration Evaporators or
Condensers — Items 114125 and 114126
CCSB Contact: Erin N. Topper
Telephone — (703) 838-8856
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
114112
114125
Sub 1
Sub 2
Sub 3
Sub 4
114126
Sub 1
Sub 2
Sub 3
Sub 4
114127
114128
Description
Class
MACHINERY GROUP: subject to item 114000
NOTE—Also applies on accompanying wrought iron or steel pipe parts.
Air Coolers or Air Conditioners, NOI; or Heat Pumps, air heating or cooling;
other than water evaporative type, with compressors, with or without
heating apparatus, see Notes, items 114112 and 114128:
Loose; on skids; or in packages other than as set forth in sub 2 ................ 110
In boxes, crates or Packages 2475 or 2476:
Handling dimension, see Note, item 114127, exceeding 84 inches,
or greatest dimension exceeding 90 inches ................................ 92.5
Handling dimension, see Note, item 114127, not exceeding 84 inches,
and greatest dimension not exceeding 90 inches...................... 77.5
Air Coolers or Air Conditioners, NOI, other than water evaporative type;
or Air Handlers, NOI; without compressors, with or without heating
apparatus, see Note, item 114112; Refrigeration Evaporators, NOI
(Cooling Coils or Cooling Units); or Refrigeration Condensers, NOI:
Loose; on skids; or in packages other than as set forth in sub 2 ................ 125
In boxes, crates or Packages 2475 or 2476:
Handling dimension, see Note, item 114127, exceeding 84 inches,
or greatest dimension exceeding 90 inches .............................. 100
Handling dimension, see Note, item 114127, not exceeding 84 inches,
and greatest dimension not exceeding 90 inches...................... 92.5
NOTE—Handling dimension is calculated as the distance from fork entry side of
article to side directly opposite forklift.
NOTE—Accompanying parts for installation may be in boxes.
©2014 National Motor Freight Traffic Association, Inc.
Subject 1, Page 1 of 9
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
Proposed Classification Provisions
Item
114112
114125
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
114126
114127
114128
NEW
Description
Class
MACHINERY GROUP: subject to item 114000
NOTE—No Change.
Air Coolers, Air Conditioners or Air Handling Equipment, viz.:
Air Coolers or Air Conditioners, NOI, with or without compressors or
heating apparatus;
Air Handlers, with or without heating apparatus;
Heat Pumps, air heating or cooling;
Refrigeration Condensers, NOI;
Refrigeration Evaporators (Cooling Coils or Cooling Units), NOI;
In boxes, crates or Packages 2475 or 2476, see Note, item 114128,
subject to Item 170 and having a density in pounds per
cubic foot of:
Less than 6 .......................................................................................... 200
6 but less than 10 ................................................................................ 125
10 or greater ......................................................................................... 77.5
In packages other than boxes, crates or Packages 2475 or 2476, see
Notes, items 114128 and NEW, subject to Item 170 and having
a density in pounds per cubic foot of:
Less than 6 .......................................................................................... 250
6 but less than 10 ................................................................................ 150
10 or greater ......................................................................................... 85
Air Coolers or Air Conditioners, NOI, other than water evaporative type;
or Air Handlers, NOI; without compressors, with or without heating
apparatus, see Note, item 114112; Refrigeration Evaporators, NOI
(Cooling Coils or Cooling Units); or Refrigeration Condensers,
NOI, etc ..................................................................................... Cancel; see
item 114125
NOTE—Cancel; no further application.
NOTE—No Change.
NOTE—Exposed coils or other components or parts liable to damage must be
protected by wood, corrugated fiberboard, expanded plastic or similar
material.
Subject 1, Page 2 of 9
©2014 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
Analysis
Research Project 1171
Research Project 1171 on items 114125 and 114126 was initiated in October of 2012 in
response to interpretation questions as to what products are classified in each of the two items
and numerous claims reports resulting from damage to the involved products.
In conjunction with the project, questionnaires were mailed to 387 potential shippers or
manufacturers of the involved products and 24 associations believed to represent those
shippers or manufacturers, in February and April of 2013. From those mailings, usable
information was received from eight companies; nine companies responded, but did not
provide usable data; three responded that they do not ship their products via less-thantruckload (LTL) motor carrier; and 20 reported that they do not ship or manufacture these
products. Of the associations contacted, seven responded stating that they do not represent
shippers or manufacturers of the involved products.
History of Provisions
The provisions of items 114125 and 114126 are the results of approximately 21/2 years of
cooperation between the Air-Conditioning, Heating, and Refrigeration Institute (AHRI)1 and
the motor common carrier industry. As a result of action taken on Docket 893, Subject 202
(May, 1989) item 114120, naming "Air Coolers or Air Conditioners, other than water evaporative
type…," was canceled with reference to two new items, 114125 and 114126. Note, item
114122, was canceled and reestablished as Note, item 114128. Item 123700, naming
“Refrigeration Evaporators NOI (Cooling Coils or Cooling Units), or Refrigeration Condensers
NOI,” was concurrently canceled with reference to new item 114126. Also, Package 2475 was
established.
Docket 893, Subject 16 (May, 1989), was a proposal to add another numbered
package — Package 2476 — as an alternate packaging method and an exception to the
provisions of Item (Rule) 222. That proposal was considered separately from Docket 893,
Subject 20, and was approved as docketed.
All of these provisions first appeared in Supplement 2 to NMF 100-P, effective July 31,
1989.
As a result of action taken on Docket 2010-2, Subject 10 (June, 2010), “air heating or
cooling” was added to the description for “Heat Pumps” in item 114125 to clarify intent. That
proposal was approved as docketed, and the change first appeared in Supplement 2 to NMF
100-AJ, effective August 28, 2010.
1
2
In 1989, the association’s name was Air Conditioning and Refrigeration Institute (ARI).
Section III of Docket 893.
©2014 National Motor Freight Traffic Association, Inc.
Subject 1, Page 3 of 9
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
About Air Coolers or Air Conditioners, Heat Pumps, Air Handlers, or
Refrigeration Evaporators or Condensers
Products classified in items 114125 and 114126 are designed to cool or warm a building,
room or other area or space and do not use water evaporative technology. Item 114126 also
applies on refrigeration evaporators or condensers. The size and configuration is dependent
on the unit’s intended use and function. The photos below show a few examples of products
encompassed by the two items.
Shipments of Air Coolers or Air Conditioners, Heat Pumps, Air Handlers, or
Refrigeration Evaporators or Condensers
Units are generally tendered on lift truck skids or pallets, or have an integral skid or pallet
base. In addition, they may be packaged in corrugated fiberboard containers, or protected
with corner posts, fiberboard top caps and/or plastic film, or shipped with little or no protective
packaging. Sub 1 of items 114125 and 114126 currently allow these articles to be tendered
loose, on skids, or in packages other than boxes, crates or Packages 2475 or 2476. Articles
tendered loose or not adequately protected by packaging are more susceptible to damage.
Photos on the following page show examples of “typical” shipments.
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©2014 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
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©2014 National Motor Freight Traffic Association, Inc.
Subject 1, Page 5 of 9
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SUBJECT 1
Transportation Characteristics
Density—The information of record includes 925 density observations submitted by shippers
and carriers, and observed firsthand on CCSB dock surveys3. The densities range from 1.07 to
60.00 pcf, with an average of 8.69 pcf. The overall frequency distribution below shows the
densities are distributed throughout the range, but the data can be divided into three density
groupings of less than 6 pcf, 6 but less than 10 pcf, and 10 pcf or greater.
% of Figures in Interval
Frequency Distribution
30.00%
23.57%
16.76%
20.00%
17.08%
11.35% 12.54%
10.59%
10.00%
5.19%
0.00%
1.62%
0.22% 1.08%
0.00%
Density Intervals (pcf)
When the data is evaluated on the basis of the three proposed density groupings, the
following ranges and averages are calculated.
3
Density Group (pcf)
Density Range (pcf)
Average Density (pcf)
Less than 6
6 but less than 10
10 or greater
1.07 – 5.99
6.01 – 9.96
10.00 – 60.00
4.14
7.79
14.24
Includes a dock survey at a shipper location.
Subject 1, Page 6 of 9
©2014 National Motor Freight Traffic Association, Inc.
Percentage of
Figures
28.97%
40.65%
30.38%
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
Handling—As shown in the photos on page 5, these products
are generally tendered on lift truck skids or pallets, which may
be made of wood or may be metal and an integral part of the
unit. Due to the size, weight and configuration, these products
will be handled with mechanical equipment. Handling units
may be marked with forklift instructions, directional arrows, or
labels such as “Handle with Care” and/or “Fragile.”
Stowability—While many of these products have a flat loadbearing surface on which compatible freight
may be loaded, some units are marked “Do
Not Stack,” “Do Not Double Stack” or “Do Not
Crush.” Some units even have a wooden
framework on the top to provide protection;
however, in the photo on the left, the coils are
still exposed and liable to be damaged if freight
is not carefully placed on top of the unit. Other
units may permit stacking of like-units up to a
certain number (e.g. 7 high). Additional care and attention should be taken when loading
freight adjacent to these products as side impacts can also cause damage.
Liability—There is no indication these products are unusually susceptible to theft, likely to
damage other freight, or perishable. They are not prone to spontaneous combustion or
explosion. However, these products are susceptible to damage, particularly when not
adequately packaged or protected. Three carriers reported claims ratios, based on the
information in their internal systems. One carrier reported claims ratios of 3.47% for item 114125
and 1.89% for item 114126 for a one-year4 period. Another carrier reported claims ratios of
0.30% for item 114125 and 0.24% for item 114126 for the year 2012. The third carrier reported
claims ratios of 0.93% and 1.08%, respectively, for two shipper accounts. A fourth carrier
reported that it does not handle products classified under these two items “due to [their]
inherent nature and lack of adequate packaging.” Shippers reported zero to 13 claims per
year. The value ranges from $0.20 to $10.79 per pound, with an average of $4.72 per pound.
Relationship to CCSB Policies and Guidelines
Research Project 1171 was initiated due to interpretation issues between the provisions
of items 114125 and 114126, as well as frequent damage resulting from insufficient, or the lack
of, packaging.
CCSB policy calls for classification provisions to be as clear as possible to help preclude
interpretation disputes. Carriers are not always able to identify the correct item that should be
applied on these types of products, e.g. those with or without a compressor. Therefore, it
would be in keeping with CCSB policies to cancel item 114126 with reference to item 114125,
and to concurrently amend the description of item 114125 to provide a “viz.” format in the
interest of clarification and simplification, and to apply on air coolers or air conditioners with or
without compressors.
4
August 1, 2012 – July 31, 2013
©2014 National Motor Freight Traffic Association, Inc.
Subject 1, Page 7 of 9
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SUBJECT 1
CCSB policy also calls for classification provisions to reflect a commodity’s known
transportation characteristics. Information of record indicates that the involved articles range
in density from 1.07 to 60.00 pcf, with an average of 8.69 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 research has identified several significant negative handling, stowability and liability
characteristics that must also be considered, in accordance with CCSB policies. These have
been detailed in this analysis and include such factors as the need for additional care and
attention in handling, the inability or additional care necessary to stack top freight or load
adjacent freight, and the inherent risk of damage, particularly when not adequately
packaged or protected. These considerations are evidenced by the handling and stowing
instructions and other precautionary markings frequently on the freight. However, these issues
can be mitigated, at least somewhat, when the articles are shipped in boxes, crates or
Packages 2475 or 2476.
CCSB packaging policy calls for the CCSB to establish and maintain packaging
specifications as necessary to ensure that freight is adequately protected in the motor carrier
environment, and can be handled and stowed in a manner that is reasonably safe and
practicable. Due to the articles’ susceptibility to damage, removing the allowance for loose
shipments, or shipments on skids (skid runners, not lift truck skids), would be in keeping with
CCSB packaging policies. Additionally, establishing a new Note to be referenced by item
114125 that requires exposed coils or other components or parts liable to damage to be
protected by packaging material would be in keeping with CCSB packaging policies.
The following table relates the information of record to the proposed density groupings
and CCSB guidelines for the proposed classes when tendered in boxes, crates or Packages
2475 or 2476, and the one-class adjustment for when articles are tendered in packages other
than boxes, crates or Packages 2475 or 2476.
Density Group
(pcf)
Average
Density
(pcf)
Class Based on CCSB
Density Guidelines
CCSB Minimum
Average
Density
Guideline (pcf)
Less than 6
6 but less than 10
10 or greater
4.14
7.79
14.24
200
125
77.5
4
7
13.5
Class Adjustment
Based on Handling,
Stowing and
Liability
Considerations
250
150
85
In view of the information of record, it would be in keeping with CCSB policy and
precedent to establish classes based on packaging and density, as proposed5. Such an
approach would provide a means for addressing both the wide density range as well as the
respective handling, stowing and liability characteristics.
5
The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
Subject 1, Page 8 of 9
©2014 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2014-2
SECTION I
SUBJECT 1
A similar approach was taken on Subject 5 of Docket 2013-1 (January, 2013) involving
item 124355, for washers (washing machines) or washer-extractors, laundry, other than
household. Density was determined to be the primary transportation characteristic when those
products were shipped in boxes, crates or Packages 1022 or 2426. When tendered in other
packages, they were not as well protected as when in boxes, crates or Packages 1022 or 2426
and thus presented additional stowing and liability concerns. Accordingly, classes were
predicated on packaging and density, assigning one class higher for washers or washerextractors tendered for shipment in packages other than boxes, crates or Packages 1022 or
2426. That proposal was approved as docketed, and the provisions first appeared in
Supplement 1 to NMF 100-AM, effective April 20, 2013.
This proposal would cancel Note, item 114127 as having no further application.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
©2014 National Motor Freight Traffic Association, Inc.
Subject 1, Page 9 of 9