CCSB DOCKET 2015-3
SECTION I
SUBJECT 8
Re: Automobile Lifts, Ramps or Runways
CCSB Contact: Daniel E. Horning
Telephone — (703) 838-1820
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
17760
17762
17763
20210
Sub 1
Sub 2
20230
Sub 1
Sub 2
Sub 3
Sub 4
Description
Class
Automobile Lifts, cantilever type, wheeled, electrohydraulic or
electromechanical, with or without lifting arms removed, see Notes,
items 17762 and 17763..................................................................................... 100
NOTE—Rubber cushion pads when removed from lift arms must be shipped in
boxes.
NOTE—Also applies on lifts designed for buses, trucks or similar vehicles.
Automobile Lifts, Ramps or Runways, NOI:
SU .............................................................................................................................. 250
KD; or Parts thereof, NOI, in boxes or crates ......................................................... 70
Automobile Ramps or Runways, not exceeding 50 inches in length:
SU .............................................................................................................................. 125
SU, in boxes; with two ramps, one inverted over the other or with angle iron
braces removed and two ramps nested, one within the other ............ 85
SU, in packages of four; two ramps nested, one within the other and
inverted over another nest of two ............................................................. 70
KD................................................................................................................................ 60
Proposed Classification Provisions
Item
17760
17762
17763
20210
20230
Description
Class
Automobile Lifts, cantilever type, etc ......................................................... Cancel; see
item A-NEW
NOTE—Cancel; no further application.
NOTE—Cancel; no further application.
Automobile Lifts, Ramps or Runways, etc .................................................. Cancel; see
item A-NEW
Automobile Ramps or Runways, etc........................................................... Cancel; see
item A-NEW
©2015 National Motor Freight Traffic Association, Inc.
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SUBJECT 8
Proposed Classification Provisions — Concluded
Item
Description
Class
A-NEW Lifts, Ramps or Runways, vehicle, or Parts thereof, NOI, powered or other
than powered, in packages:
Sub 1
Greatest dimension exceeding 96 inches, see Note, item B-NEW, subject
to Item 170 and having a density in pounds per cubic foot of:
Sub 2
Less than 15 ....................................................................................................... 125
Sub 3
15 or greater ........................................................................................................ 77.5
Sub 4
Greatest dimension not exceeding 96 inches, see Note, item B-NEW,
subject to Item 170 and having a density in pounds per cubic
foot of:
Sub 5
Less than 15 ....................................................................................................... 110
Sub 6
15 or greater ........................................................................................................ 70
B-NEW NOTE—Greatest dimension refers to the longest straight-line dimension of the
handling unit as tendered for shipment.
Analysis
Research Project 1228
Research Project 1228 on automobile lifts, ramps or runways was initiated in April 2014 to
address interpretation issues and to develop current information on the transportation
characteristics of the involved products. The interpretation questions revolve around the
proper application of items 17760, 20210 and 20230, and the distinctions between various lifts,
ramps and runways – especially the determination of whether or not a commodity is fully
knocked down (KD), in compliance with Item (Rule) 110, Sec. 12(c).
As part of the research, the CCSB mailed commodity questionnaires to 51 potential
manufacturers or shippers, and eight trade associations believed to represent those
manufacturers or shippers. An initial mailing went out in May 2014, and a second mailing was
sent in July 2014 to non-respondents, inviting them to participate in the research. Of the
companies contacted, six responded that they do not manufacture or ship the products,
while three firms responded with usable information. There were no responses received from
any of the associations.
History of Provisions
Item 17760, along with Note, item 17762, was established as a result of action taken on
Docket 822, Subject 18 (March 1982) and first appeared in Supplement 11 to NMF 100-I,
effective December 4, 1982. The information of record indicated a density of 9.9 pcf, along
with a value per pound of $1.57 (in 1982 dollars). The provisions were further amended as a
result of action taken on Docket 913, Subject 14 (May 1991) by amending the description to
read ‘electro-mechanical’ and the addition of Note, item 17763. Those changes first
appeared in Supplement 3 to NMF 100-R, effective August 3, 1991.
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©2015 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2015-3
SECTION I
SUBJECT 8
The provisions for automobile lifts or runways, as currently named in item 20210, were
adopted from the rails in 1936. As a result of action taken on Special Docket No. 1 (issued July
20, 1949), the rating for set up (SU) products was altered to class 250. Further amendments and
clarifications resulted from Docket 751, Subject 14 (January 1975), allowing for replacement
parts and shipments in boxes or crates. Information of record indicated an average density of
21 pcf, with a value of $2.00 per pound (in 1975 dollars). Those changes first appeared in
Supplement 11 to NMF 100-B, effective September 10, 1975.
The provisions of item 20230 were established as a result of action taken on Docket 723,
Subject 27 (May 1972) and first appeared in Supplement 20 to NMF 100, effective October 19,
1973. The current classes and subprovisions were established as a result of action taken on
Docket 766, Subject 7 (September 1976) and first appeared in Supplement 1 to NMF 100-D,
effective April 2, 1977. The provisions have remained substantially unchanged to the present.
About Vehicle Lifts, Ramps or Runways
Vehicle lifts are powered hoisting devices used to elevate the entire vehicle body
(whether for servicing, inspection or storage) and then lower it. Information developed from
research indicates vehicle lifts may be utilized for both highway and off-highway vehicles.
There are numerous lifts on the market today for professional shops, commercial lots or
garages, and home enthusiasts. Product options include 2-post or 4-post lifts, parking lifts,
alignment lifts, and other specialty lifts. Alternatively, vehicle ramps or runways serve as inclines
or planes and generally do not provide a lifting function, but may have mechanical height
adjustment features. Depending on the specific size and model, they allow for underside
inspection, service access, loading or display. Examples of the involved commodities are
shown below and on the following page.
LIFTS
2-Post
4-Post
Parking
©2015 National Motor Freight Traffic Association, Inc.
Cantilever
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SUBJECT 8
RAMPS OR RUNWAYS
Car Ramp
Display
Trailer
Plastic
Transportation Characteristics
Density—The Information of record includes 14,859 density observations submitted by shippers
and carriers, collected during CCSB dock surveys and obtained from the CCSB’s Density
Study1. The products range in density from 1.39 to 148.92 pcf, with an average density of 22.06
pcf. The frequency distribution is shown below.
% of Figures in Interval
Frequency Distribution
40.00%
32.64% 33.97%
30.00%
20.00%
9.15%
10.00%
11.74%
3.18% 3.80% 3.54%
0.00% 0.05% 0.30% 1.62%
0.00%
Density Intervals (pcf)
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.
1
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©2015 National Motor Freight Traffic Association, Inc.
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SUBJECT 8
When the data is evaluated based on greatest dimension, where known, handling units
with greatest dimension not exceeding 96 inches range in density from 1.79 to 70.25 pcf, with
an average density of 18.93 pcf. The following table shows the data for handling units having
greatest dimension not exceeding 96 inches when it is evaluated with a single density break at
15 pcf.
Density Group (pcf)
Less than 15
15 or greater
Density Range (pcf)
1.79 – 14.82
15.00 – 70.25
Average Density (pcf)
9.62
24.35
Handling units of vehicle lifts, ramps or runways with greatest dimension exceeding 96
inches range in density from 2.16 to 70.10 pcf, with an average density of 21.70 pcf. The table
below shows the data for handling units having greatest dimension exceeding 96 inches when
evaluated with a single density break at 15 pcf.
Density Group (pcf)
Less than 15
15 or greater
Density Range (pcf)
2.16 – 14.85
15.13 – 70.10
Average Density (pcf)
9.54
25.31
Handling—The vast majority of the involved articles are shipped disassembled, although in
some instances, ramps were reported to be shipped set up or assembled. Given the
numerous designs, configurations and shapes, vehicle lifts, ramps or runways may be tendered
in a variety of ways that can have an impact on the carrier’s ability to safely handle the
freight. They may be in boxes, bundles, strapped on a shipping rack, cradles, or lift truck skids
or pallets. Units tendered in bundles or on lift truck skids or pallets may or may not have
protective packaging, such as plastic film or fiberboard. Commodities equipped with sensitive
instrumentation require additional care and attention during handling. Additionally, handling
units may be marked with forklift instructions, directional arrows or labels such as “Do Not
Stack,” “Warning – Do Not Lift From This End,” “Fork Here,” among others2. Where the greatest
dimension exceeds 96 inches3, additional equipment, such as fork extensions or additional
personnel, may be necessary to safely handle the freight. Depictions of various shipping forms
and manner of tender are shown on the following page.
Other labels that have been observed include “Attention: Inspect and Note Any Damage Before
Accepting Delivery,” “Units Tall and Awkward,” ”Must Be Strapped Down,” “Block and Brace,” “Do Not
Fork Here” and “Top Heavy.”
3 Item (Rule) 568, for Heavy or Bulky Freight—Loading or Unloading, employs the threshold limit of
exceeding 8 feet (96 inches) in greatest dimension as the measurement at which the consignor will
perform the loading and the consignee will perform the unloading.
2
©2015 National Motor Freight Traffic Association, Inc.
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CCSB DOCKET 2015-3
SECTION I
SUBJECT 8
Stowability—When shipped in bundles or without protective packaging on lift truck skids or
pallets, these units may present stowing concerns due to the lack of regular load-bearing
surfaces. With lift assemblies weighing up to 500 pounds or more, most, if not all, will require
floor loading. Moreover, handling units have been shown to exceed 96 inches in greatest
dimension, while some shipments have been observed with a “high clearance” warning. In this
regard, consideration must be given to stowing only compatible freight adjacent to these units
if damage is to be avoided. Handling units with exposed edges have the potential to scuff,
scratch, dent or otherwise damage adjacent freight. This can impede the carriers’ ability to
structure a load and maximize vehicle utilization.
Liability—Vehicle lifts, ramps or runways are not perishable, susceptible to theft, nor hazardous
in nature. However, when tendered in bundles or on lift truck skids or pallets without protective
packaging, they may be susceptible to damage or more likely to damage adjacent freight.
Only two value per pound figures were reported, $1.46 and $1.93. One shipper respondent
indicated two and four claims, respectively, per year on two separate models. Reporting by
NMFC® item number, one carrier indicated claims ratios of 1.5% for item 17760 and 0.4% for
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©2015 National Motor Freight Traffic Association, Inc.
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SUBJECT 8
item 20210. Reporting by customer, a second carrier indicated two damage claims for a 2.26%
claims ratio for shipper 1, 0.75% for shipper 2, and 12.71% for shipper 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, combining descriptions embracing related commodities and providing
uniformity in provisions addressing the same or similar circumstances. There have been
interpretation questions regarding the proper application of items 17760, 20210 and 20230,
and the distinctions between various vehicle lifts, ramps and runways – especially the
determination of whether or not a commodity is fully knocked down (KD) in compliance with
Item (Rule) 110, Sec. 12(c). Canceling items 17760, 20210 and 20230 with reference to a new
item, as proposed, would address the interpretation issues and would be consistent with CCSB
policy.
CCSB policy also calls for provisions to reflect a commodity’s known transportation
characteristics and states that when commodities exhibit a wide range in densities, classes
may be assigned based on density. Vehicle lifts, ramps or runways range in density from 1.39 to
148.92 pcf, with an average of 22.06 pcf. An average density of 22.06 pcf is generally
associated with class 70, which calls for a minimum average density of 15 pcf. However, CCSB
policies also state that unusual or significant negative handling, stowing or liability
characteristics may be contributing factors in the assignment of classes. In this instance,
research has identified several significant negative handling, stowability and liability issues that
must also be considered, in accordance with CCSB policies. These factors have been detailed
in the analysis and include such issues as the need for floor-loading and the inability to tier
shipments due to the lack of a flat load-bearing surface. Further handling and stowing
difficulties are presented by these articles when tendered in handling units exceeding 96
inches in greatest dimension. Classification precedent has been to assign a higher class than
that usually associated with density when unusual or significant handling, stowability and/or
liability characteristics are identified.
In view of the information of record, it would be in keeping with CCSB policy to establish
provisions based on greatest dimension and density, as shown in the table on the following
page4. One set of classes predicated on greatest dimension not exceeding 96 inches with a
density break at 15 pcf that are one-class higher than that called for by CCSB density
guidelines would be established. A companion set of classes would be established for articles
with greatest dimension exceeding 96 inches, also with a density break at 15 pcf, but two
classes higher than that associated with the density guidelines.
4
The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
©2015 National Motor Freight Traffic Association, Inc.
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SUBJECT 8
Density Group
(pcf)
Average Density (pcf)
Greatest Dimension
Not Exceeding/
Exceeding 96’’
Class Based on
CCSB Density
Guidelines
Less than 15
15 or greater
9.62 / 9.54
24.35 / 25.31
100
65
One-Class
Adjustment for
Greatest
Dimension Not
Exceeding 96”
110
70
Two-Class
Adjustment for
Greatest
Dimension
Exceeding 96”
125
77.5
Notes, items 17762 and 17763 would be canceled. A new, attendant Note, would be
established, stating “Greatest dimension refers to the longest straight-line dimension of the
handling unit as tendered for shipment.” These changes would be in keeping with CCSB
policies with respect to clarification.
This proposal is also consistent with classification precedent. As a result of action taken
on Docket 2013-3, Subject 1 (September 2013), item 86700, naming flat glass, was amended to
provide classes based on greatest dimension of the handling unit as tendered for shipment,
and density, with a one-class adjustment from CCSB guidelines where greatest dimension does
not exceed 96 inches, and a two-class adjustment where greatest dimension exceeds 96
inches, reflecting the respective handling, stowing and liability considerations. The proposal
was approved as docketed, and the provisions first appeared in Supplement 4 to NMF 100AM, effective December 14, 2013.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
Subject 8, Page 8 of 8
©2015 National Motor Freight Traffic Association, Inc.