CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Re: Grading or Road Making Attachments or Implements
CCSB Contact: William F. Mascaro
Telephone — (703) 838-1834
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
122000
122020
122040
122060
Sub 1
Sub 2
122065
122080
122120
122140
Sub 1
Sub 2
122160
122200
122240
122260
122280
122300
122320
122340
122380
122420
122422
122520
122522
Description
Class
MACHINERY GROUP: subject to item 114000
Grading or Road Making Implements:
Blades, or Cutting Edges, grader or scraper, steel ........................................ 55
Bulldozer Attachments, consisting of root rakes or rock rakes, on skids, or
stumper blades, loose or on skids......................................................... 65
Discs, road grader:
Loose or in bundles if weighing each 25 pounds or over ....................... 70
In boxes or crates ......................................................................................... 65
Drums, Rotors or Wheels, scarifier, iron or steel, without cutting teeth,
banded to pallets or skids ..................................................................... 85
Graders or Levelers, drag .................................................................................. 85
Graders and Self-propelling Road Rollers combined ................................. 100
Graders, wheeled:
SU, wheels on or off .................................................................................... 125
KD.................................................................................................................... 77.5
Road Scraper Bails ........................................................................................... 100
Rollers, road, self-propelling or other than self-propelling ............................ 85
Sand or Gravel Spreaders, mounted on freight automobile chassis ........ 150
Sand or Gravel Spreaders, NOI ........................................................................ 85
Scarifiers ............................................................................................................... 77.5
Scarifiers and Mixers combined, power ....................................................... 100
Scarifier Teeth or Tooth Bases (Shanks) ........................................................... 55
Scrapers, NOI, drag, horse or tractor drawn, not wheeled.......................... 77.5
Steering Poles or Guides, grader...................................................................... 77.5
Tractors and Tractor Excavating, Grading or Loading Attachments
combined, see Note, item 122422, or Motor Graders ..................... 100
NOTE—Parts of the attachment may be removed when necessary to facilitate
loading or provide safe highway clearance.
Grading or Road Making Implement Parts, iron or steel, NOI, see Note,
item 122522.................................................................................................... 85
NOTE—Also applies on parts made of a combination of iron or steel and other
materials, provided the weight of the other materials does not exceed 20
percent of the total weight of such combined parts.
©2016 National Motor Freight Traffic Association, Inc.
Subject 3, Page 1 of 9
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Proposed Classification Provisions
Item
122000
Sub 1
Sub 2
Sub 3
A-NEW
B-NEW
C-NEW
122020
122040
122060
Description
Class
MACHINERY GROUP: subject to item 114000
Grading or Road Making Attachments or Implements, viz.:
Blades or Cutting Edges, grader or scraper, steel, see Notes, items
A-NEW, B-NEW and C-NEW;
Graders, NOI, Levelers or Scrapers;
Graders and Self-Propelled Road Rollers combined;
Grading or Road Making Attachment or Implement Parts, NOI, iron
or steel;
Rollers, grading or road;
Root Rakes, Rock Racks or Stumper Blades, bulldozer;
Scarifier Drums, Rotors or Wheels, iron or steel, without cutting teeth;
Scarifier Teeth or Tooth Bases (Shanks);
Scarifiers or Scarifiers and Mixers combined;
Spreaders, gravel or sand;
Tractors and Tractor Excavating, Grading or Loading Attachments
combined;
In packages, subject to Item 170 and having a density in pounds
per cubic foot of:
Less than 12 ........................................................................................... 175
12 but less than 30 .................................................................................. 85
30 or greater ............................................................................................ 60
NOTE—Applies on blades or cutting edges with or without permanently affixed
mounting brackets.
NOTE—Does not apply on blades or cutting edges for moving, plowing or
pushing snow. For applicable provisions, see items 130190 and 130195.
NOTE—Does not apply on blades or cutting edges equipped with mounts,
arms or devices for attaching to tractors or trucks. For applicable
provisions, see item 114220.
Blades, or Cutting Edges, grader or scraper, etc.......................... Cancel; see
item 122000
Bulldozer Attachments, consisting of root rakes or rock rakes,
on skids, or stumper blades, etc. ......................................... Cancel; see
item 122000
Discs, road grader, etc. .................................................................... Cancel; see
item 122000
Subject 3, Page 2 of 9
©2016 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Proposed Classification Provisions — Concluded
Item
122065
122080
122120
122140
122160
122200
122240
122260
122280
122300
122320
122340
122380
122420
122422
122520
122522
Description
Class
MACHINERY GROUP: subject to item 114000
Grading or Road Making Attachments or Implements: subject to
item 122000
Drums, Rotors or Wheels, scarifier, iron or steel, without cutting
teeth, etc. ............................................................................... Cancel; see
item 122000
Graders or Levelers, drag ................................................................. Cancel; see
item 122000
Graders and Self-propelling Road Rollers combined .................. Cancel; see
item 122000
Graders, wheeled, etc...................................................................... Cancel; see
item 122000
Road Scraper Bails ............................................................................ Cancel; see
item 122000
Rollers, road, self-propelling or other than self-propelling ........... Cancel; see
item 122000
Sand or Gravel Spreaders, mounted on freight automobile
chassis ..................................................................................... Cancel; see
item 122000
Sand or Gravel Spreaders, NOI ....................................................... Cancel; see
item 122000
Scarifiers .............................................................................................. Cancel; see
item 122000
Scarifiers and Mixers combined, power ........................................ Cancel; see
item 122000
Scarifier Teeth or Tooth Bases (Shanks) .......................................... Cancel; see
item 122000
Scrapers, NOI, drag, horse or tractor drawn, not wheeled......... Cancel; see
item 122000
Steering Poles or Guides, grader..................................................... Cancel; see
item 122000
Tractors and Tractor Excavating, Grading or Loading Attachments
combined, see Note, item 122422, or Motor Graders ...... Cancel; see
item 122000
NOTE—Cancel; no further application.
Grading or Road Making Implement Parts, iron or steel, NOI, see
Note, item 122522 ........................................................................ Cancel; see
item 122000
NOTE—Cancel; no further application.
©2016 National Motor Freight Traffic Association, Inc.
Subject 3, Page 3 of 9
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Analysis
Research Project 1214
This proposal is based on information developed through Research Project 1214, which
was initiated in January of 2014 to investigate the transportation characteristics of grading or
road making implements, as named in the various NMFC items shown in the Present
Classification Provisions, in response to interpretative issues.
As part of the research, the CCSB mailed commodity questionnaires to 170 potential
manufacturers or shippers of the involved commodities and seven trade associations believed
to represent those manufacturers or shippers, inviting them to participate in the research. The
surveys were mailed in June of 2014, and again in July of 2014 to those that did not respond to
the initial mailing. From this sampling, eight companies responded that they did not
manufacture or ship the involved articles, and eight companies provided information,
although not all of the responding companies provided information on the transportation
characteristics of their products. Two associations indicated that they did not represent
manufacturers or shippers of the involved articles. No responses were received from the other
associations.
History of Provisions
Items 122020, 122060, 122080, 122120, 122140, 122160, 122200, 122240, 122260, 122280,
122300, 122320, 122340, 122380 and 122520 were adopted from the rail classification in 1936.
Since that time, a few of these provisions have been changed, although the majority have
remained substantially unchanged.
The provisions of item 122040, naming bulldozer attachments, consisting of root rakes,
rock rakes or stumper blades, were established as a result of action taken on Docket 38,
Subject 32 (October 1948). The record did not provide specific information related to the
transportation characteristics of the involved articles, but did cite weights ranging from 1,950
to 3,975 pounds and values ranging from $570.00 to $1,200.00 (in 1948 dollars) for root or rock
rakes. Stumper blades were reported to range in weight from 1,200 to 2,650 pounds and range
in value from $400.00 to $1,200.00 (in 1948 dollars). That proposal was approved as modified,
and the provisions first appeared in Supplement 20 to NMFC No. 9, effective March 5, 1949.
The provisions of item 122065, naming scarifier drums, rotors or wheels, were established
as a result of action taken on Docket 913, Subject 9 (May 1991). That was a proposal to
establish a specific provision for these articles. Information of record showed a density range
from 58.89 to 116.43 pcf, with a simple average density of 79.26 pcf. Drums or rotors exhibited
values ranging from $1.85 to $2.55 per pound, while wheels were found to have a value of
$4.15 per pound (all in 1991 dollars). The record also cited negative handling, stowing and
liability concerns. The proposal was approved as modified, and the provisions first appeared in
Supplement 3 to NMF 100-R, effective October 5, 1991.
The provisions of item 122420, naming tractors and tractor excavating, grading or
loading attachments combined, or motor graders, were established as a result of action taken
on Docket 57, Subject 36 (January 1953). The supporting documentation for that proposal is no
Subject 3, Page 4 of 9
©2016 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
longer available. The provisions first appeared in Supplement 24 to NMFC No. 11, effective
August 11, 1953.
About Grading or Road Making Attachments or Implements
The involved articles are generally used to prepare or finish earthen surfaces for roads,
and related applications. Uses include land clearing, grading, leveling and compacting, as
well as smoothing, spreading and other related functions. Depending upon the intended
application, they may be pushed or pulled by a tractor or motorized vehicle, or they may be
self-propelled. Others are mounted alongside or behind a tractor or motorized vehicle.
Examples of various types of grading or road making attachments or implements are shown
below.
©2016 National Motor Freight Traffic Association, Inc.
Subject 3, Page 5 of 9
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Transportation Characteristics
Density—The information of record is based on data submitted by shippers and carriers,
obtained during CCSB dock surveys and obtained from the CCSB’s Density Study1. Combined,
these sources yield 10,172 density observations on articles reported to be moving under the
provisions of the involved items. The densities range from 1.00 to 405.00 pcf, with an average of
32.34 pcf.
The table below provides an evaluation of the data on the basis of the three proposed
density groupings, which results in the following ranges and averages.
Density Group (pcf)
Density Range (pcf)
Average Density (pcf)
Less than 12
12 but less than 30
30 or greater
1.00 – 11.99
12.00 – 29.99
30.00 – 405.00
7.74
17.63
82.52
Handling—Grading or road making attachments or implements are generally tendered loose2
or secured on lift truck skids or pallets, with little or no protective packaging. The involved
attachments or implements, due to their size, weight and/or configuration, are more difficult to
handle than general boxed freight and require additional equipment, such as fork extensions,
or additional personnel to safely handle.
Stowability—Grading or road making attachments or implements tendered loose or secured
on lift truck skids or pallets present some significant negative stowability considerations. In
general, these articles will require floor loading due to their size and weight. Articles tendered
in this manner will generally lack a flat load-bearing surface for the stowing of other freight on
top. They may also lack lateral support for freight loaded adjacent to them in the vehicle.
Additionally, grading or road making attachments or implements may have protrusions and/or
exposed surfaces or edges that can limit the type of freight that may safely be loaded
adjacent to them. In the LTL environment, this means that carriers will either not be able to
load other freight on top of or adjacent to the unit, or that they will have to employ the use of
load decks and/or dunnage, resulting in an associated increase in time necessary to properly
structure the load.
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 While many of the current provisions do not require any packaging and the freight can, therefore, be
shipped loose, the proposed provisions would require the involved articles to be tendered “in
packages.”
1
Subject 3, Page 6 of 9
©2016 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Liability—Grading or road making attachments or implements are not perishable, hazardous in
nature or susceptible to theft. They may be susceptible to damage depending on the
particular attachment or implement and/or the manner in which they are tendered for
shipment. In addition to having an impact on susceptibility to damage, the manner in which a
particular attachment or implement is tendered for shipment will also have an impact on its
propensity to damage other freight. Grading or road making attachments or implements
shipped with little or no protective packaging may have protrusions and/or exposed surfaces
or edges that can puncture, mar or otherwise damage adjacent freight. Also, shipments
loaded in a vehicle are generally supported to some extent by adjacent freight. When these
articles are tendered loose or on lift truck skids or pallets, they may not provide sufficient lateral
support for adjacent freight, which can result in damage to either the article itself or the
adjacent freight. However, there is no indication of a claims problem. The information of
record on the value of grading or road making attachments or implements indicates a range
from $2.22 to $9.55 per pound, with an average value of $5.32 per pound.
Photographs of grading or road making attachments or implements as tendered for
shipment are shown below and on the following page.
©2016 National Motor Freight Traffic Association, Inc.
Subject 3, Page 7 of 9
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Relationship to CCSB Policies and Guidelines
CCSB policy calls for provisions to be as clear as possible to mitigate the potential for
interpretation disputes. CCSB policy also calls for provisions to reflect a commodity’s known
transportation characteristics. Information of record has found densities for the involved
articles ranging from 1.00 to 405.00 pcf, with an average density of 32.34 pcf. CCSB policy
states that when commodities or commodity groups exhibit a wide density range not
accurately reflected by a single overall average density, density-based classes may be
established. The data of record can be divided into three density groupings of less than 12 pcf,
12 but less than 30 pcf, and 30 pcf or greater. The table below shows the classes associated
with each respective average density based on CCSB guidelines.
Density Group (pcf)
Average Density
(pcf)
CCSB Minimum
Average Density
Guideline (pcf)
Class Based on
CCSB Density
Guidelines
Less than 12
7.74
7
125
12 but less than 30
17.63
15
70
30 or greater
82.52
50
50
CCSB policy further states that unusual or significant negative handling, stowability or
liability characteristics may be contributing factors in the assignment of classes. Negative
handling, stowability and liability concerns have been detailed in this analysis. These concerns
include factors such as the need for additional equipment or personnel to safely handle the
freight, the lack of a load-bearing surface for top freight and lack of lateral support for
adjacent freight, and the articles’ susceptibility to be damaged and likelihood of damaging
other freight.
Subject 3, Page 8 of 9
©2016 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2016-2
SECTION I
SUBJECT 3
Based on the identified negative handling, stowing and liability concerns, classification
precedent has been to assign classes higher than those associated with the CCSB density
guidelines. This proposal would establish classes based on density3, with a two-class adjustment
based on the average density of each grouping, as shown in the table below.
Density Group (pcf)
Average
Density (pcf)
Class Based on
CCSB Density
Guidelines
Class Adjustment Based on
Handling, Stowability and
Liability Considerations
Less than 12
7.74
125
175
12 but less than 30
17.63
70
85
30 or greater
82.52
50
60
In addition to providing classes reflective of the transportation characteristics of the
involved articles, this proposal would also establish three new Notes clarifying grader or
scraper blades or cutting edges. Notes, items 122422 and 122522 would be canceled as
having no further application.
Precedent for this approach can be found on Docket 2013-2, Subject 12 (June 2013)
involving snowplows, snowplow blades (moldboards) or snow pushers, vehicle or tractor
attaching; or mounts, arms or devices, snowplow or snow pusher attaching, as named in item
130195. In that instance, the CCSB approved provisions based on a density break at 10 pcf,
wherein the involved articles were assigned classes representing a two-class adjustment from
those called for under CCSB guidelines for each density group, in view of their respective
negative handling, stowability and liability characteristics. The changes first appeared in
Supplement 2 to NMF 100-AM, effective August 24, 2013.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
3
The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
©2016 National Motor Freight Traffic Association, Inc.
Subject 3, Page 9 of 9