CCSB DOCKET 2013-3
SECTION I
SUBJECT 1
Re: Flat Glass — Item 86700
CCSB Contact: Daniel E. Horning
Telephone — (703) 838-1820
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
86700
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
86701
86702
Description
Class
GLASS: subject to item 86500
Glass, flat, NOI, see Note, item 86701:
Bent, in boxes or crates:
220 united inches or less ............................................................................ 85
Exceeding 220 united inches but not exceeding 15 feet in length nor
9 feet in width ............................................................................... 100
Exceeding 15 feet in length or 9 feet in width ....................................... 250
Not bent, see Note, item 86702, in boxes, crates or Packages 195, 198,
235, 785, 2008, 2025, 2147, 2149, 2160, 2239, 2245, 2281 or 2497:
220 united inches or less ............................................................................ 65
Exceeding 220 united inches but not exceeding 15 feet in length nor
9 feet in width ............................................................................... 100
Exceeding 15 feet in length or 9 feet in width ....................................... 200
NOTE—The term ‘flat’ applies to glass known as sheet, plate, polished prism,
rolled, window or float glass, whether or not polished, laminated, colored,
opalescent, opaque, chipped, decorated, wired, etched, figured, acid
dipped, ground, sandblasted, metalized (sprayed with atomized metal
while glass is hot) or tempered, but not when silvered for mirrors, nor
flashed, nor framed or leaded (set in or framed by lead or other metal).
NOTE—Flat glass, not bent, may also be cut to size, edges beveled or ground,
or holes cut or drilled.
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©2013 National Motor Freight Traffic Association, Inc.
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Proposed Classification Provisions
Item
86700
Sub 1
Sub 2
Sub 3
Sub 4
Sub 5
Sub 6
Sub 7
Sub 8
86701
86702
NEW
Description
Class
GLASS: subject to item 86500
Glass, flat, bent or not bent, NOI, see Notes, items 86701 and 86702, in
boxes, crates or Packages 195, 198, 235, 785, 2008, 2025, 2147, 2149,
2160, 2239, 2245, 2281 or 2497:
Greatest dimension exceeding 96 inches, see Note, item NEW, subject
to Item 170 and having a density in pounds per cubic foot of:
Less than 8 ................................................................................................ 300
8 but less than 12 ..................................................................................... 125
12 or greater ............................................................................................... 85
Greatest dimension not exceeding 96 inches, see Note, item NEW,
subject to Item 170 and having a density in pounds per cubic
foot of:
Less than 8 ................................................................................................ 250
8 but less than 12 ..................................................................................... 110
12 or greater ............................................................................................... 77.5
NOTE—No Change.
NOTE—No Change.
NOTE—Greatest dimension refers to the longest straight-line dimension of the
handling unit as tendered for shipment.
Analysis
Research Project 1165
Research Project 1165 was initiated in July 2012 in response to reports that shipments of
flat glass exhibited densities inconsistent with the provisions of item 86700. Item 86700 currently
provides for glass either bent or not bent, subject to one of six classes, with final determination
predicated on the size of the glass.
During the project, questionnaires were sent to 74 potential manufacturers or shippers
and 13 trade associations related to the glass industry. Mailings were sent in October 2012,
and for non-respondents, a second, follow-up letter was sent in December 2012. From those
mailings, two companies responded with usable information; three firms did not provide
usable data; one responded that they do not manufacture or ship flat glass, and one
questionnaire went unclaimed. Of the associations contacted, five responded, indicating that
they do not represent manufacturers or shippers of flat glass. Additional information was
developed through CCSB dock surveys and carrier-submitted reports.
History of Provisions
The original provisions for flat glass were adopted from the rails in 1936 and first
appeared in LTL-1. The provisions have been amended over the years. The last significant
change occurred as a result of action taken on Subject 39 of Docket 120 (September 1965),
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which established the present alignment and classes. The change first appeared in
Supplement 13 to NMFC A-9, effective September 27, 1967.
About Flat Glass
As per the Note, item 86701, the term “flat” applies to glass known as sheet, plate,
polished prism, rolled, window or float glass, whether or not polished, laminated, colored,
opalescent, opaque, chipped, decorated, wired, etched, figured, acid dipped, ground,
sandblasted, metalized (sprayed with atomized metal while glass is hot) or tempered, but not
when silvered for mirrors, nor flashed, nor framed or leaded (set in or framed by lead or other
metal).
Shipments of Flat Glass
Among the many precautionary warnings affixed to glass shipments is the restriction
that glass is not to be laid flat. As a consequence, most, if not all forms are mounted on edge,
vertically oriented, and in most cases, supported by outriggers in an A-frame configuration or
something similar. This applies whether the glass is bent or not. Alternatively, some shipments
have been observed in crates. Various depictions are provided below and on the following
page.
©2013 National Motor Freight Traffic Association, Inc.
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Transportation Characteristics
Density—The information of record includes 336 density figures ranging from 1.11 to 58.91 pcf,
with an average density of 7.99 pcf. As depicted in the following graph, the densities are
distributed throughout the range. However, the data can be divided into three density
groupings of less than 8 pcf, 8 but less than 12 pcf, and 12 pcf or greater.
% of Figures in Interval
Frequency Distribution
23.21%
21.73%
25.00%
17.86%
20.00%
15.00%
8.93% 7.74% 7.74%
10.00%
5.00%
6.25%
3.57%
1.49% 1.49%
0.00%
0.00%
Density Intervals (pcf)
Flat glass shipments with greatest dimension not exceeding 96 inches have an average
density of 8.43 pcf, with a range of 1.11 to 58.91 pcf, as depicted in the frequency distribution
on the following page.
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% of Figures in Interval
Greatest Dimension Not Exceeding 96"
23.98%
25.00%
18.70%
20.00%
18.29%
15.00%
9.35% 8.54% 9.35%
10.00%
5.00%
0.00%
6.10%
2.44%
1.22% 2.03%
0.00%
Density Intervals (pcf)
The following table shows the data for flat glass having greatest dimension not
exceeding 96 inches when it is evaluated with two density breaks at 8 and 12 pcf.
Density Group
Less than 8
8 but less than 12
12 or greater
Density Range (pcf)
1.11 - 7.98
8.07 - 11.95
12.03 - 58.91
Average Density (pcf)
4.84
9.90
19.20
Flat glass shipments with greatest dimension exceeding 96 inches range in density from
1.14 to 26.39 pcf, for an average density of 6.76 pcf, as illustrated in the following graph.
% of Figures in Interval
Greatest Dimension Exceeding 96"
30.00%
30.00%
21.11%
16.67%
25.00%
20.00%
15.00%
10.00%
5.00%
6.67%
7.78%
5.56%
6.67%
3.33%
0.00%
2.22%
0.00%
0.00%
Density Intervals (pcf)
©2013 National Motor Freight Traffic Association, Inc.
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The table below shows the data for flat glass having greatest dimension exceeding 96
inches when it is evaluated with two density breaks at 8 and 12 pcf.
Density Group
Less than 8
8 but less than 12
12 or greater
Density Range (pcf)
1.14 - 7.91
8.01 - 11.76
12.46 - 26.39
Average Density (pcf)
4.36
9.70
18.21
Handling—Flat glass is inherently fragile and therefore requires due diligence and special
attention in vehicle loading, unloading and in cross-docking procedures. Shipments are often
labeled or marked with directional arrows and other handling instructions such as “Fragile,”
“Handle With Care,” “Keep Braced At All Times,” “Case Must Remain on Pallet,” “This Side Up,”
“Do Not Lean or Lay Flat,” among others1. Flat glass exceeding 96 inches in greatest
dimension presents additional considerations for the carrier2. As greatest dimension increases,
the handling into and out of the vehicle, and cross-dock operations, become considerably
more difficult, and certain equipment, or additional personnel, may be necessary to safely
handle the freight.
Stowability—Product shipments are packaged in a variety of forms but are generally tendered
vertically oriented, on edge in some kind of A-frame or rack structure (when not in crates or
wooden cases or boxes), and are usually supported by outriggers or customized bracing. Due
to the configuration and size of the handling units, carriers are generally restricted to floor
loading, and may have difficulty loading other goods around these commodities as the units
typically do not provide lateral support for adjacent freight. Due to the specific nature of glass
and restrictions on double stacking or loading other freight on top, carriers are prevented from
utilizing all available vehicle space. Flat glass exceeding 96 inches in greatest dimension
presents additional difficulties for the carrier in structuring a vehicle load.
Liability—Glass is not perishable, prone to spontaneous combustion or explosion or unusually
susceptible to theft. A limited amount of information available on the value of the involved
glass indicates a range from $0.10 to $5.69 per pound, with an average value of $3.04 per
pound.
Carrier claims personnel were contacted, and while no information was submitted that
would indicate an unusual or significant damage problem, flat glass may be more susceptible
to damage than other types of general freight due to its inherent fragility. This potential has
long been recognized in the NMFC™ through more explicit packaging requirements and
handling instructions. In this regard, Note, item 86512, governing the Glass generic heading,
states in part, ‘shipments must be so packed and so loaded that glass rests on full flat edge.
Glass, other than tempered, when shipped in containers other than those requiring
mechanical handling equipment, must be conspicuously marked on two flat sides as follows.’
Other labels that have been observed include “Glass – Do Not Drop,” “Do Not Double Stack,” “Keep
Dry,” “Do Not Break Down Skid.”
2 Item (Rule) 568, 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 freight becomes more
difficult to load and unload when compared to general freight.
1
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Additionally, the manner in which flat glass is tendered for shipment may also have an
impact on its susceptibility to damage. As noted, glass packaging generally does not provide
lateral support for adjacent freight. Outriggers and other forms of bracing may be of sufficient
strength to hold and stabilize glass sheets in an upright position during transit, but may not be
able to support the additional load of co-loaded freight.
Relationship to CCSB Policies and Guidelines
CCSB policy calls for provisions to reflect a commodity’s known transportation
characteristics. Information of record reveals that movements of flat glass—whether bent or
not bent—are shipped on edge (as required), in varying lengths and sizes. CCSB policy further
provides that where commodities or commodity groups exhibit a wide range of densities not
accurately reflected by a single class they may be assigned density-based classes. However,
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, the
inability to tier shipments and the inherent fragile nature of glass, among others, with yet
additional handling and stowing difficulties presented by glass exceeding 96 inches in greatest
dimension. Classification precedent has been to assign a higher class than that associated
with the CCSB’s density guidelines when there are unusual or significant handling, stowability
or liability characteristics.
In view of the information of record, it would be in keeping with CCSB policy and
classification precedent to establish provisions based on greatest dimension and density, as
proposed3. As outlined in the discussion of density, the density figures are distributed
throughout the range, but can be segregated into three clusters or groupings of less than 8
pcf, 8 but less than 12 pcf, and 12 pcf or greater. The table shown on the following page
provides an evaluation of the density information of record on the basis of the three proposed
density groups and shows the respective average density, the class based on CCSB density
guidelines, and class adjustments to reflect the identified negative handling, stowing and
liability considerations.
3
The density provisions would include reference to Item (Rule) 170, the inadvertence clause.
©2013 National Motor Freight Traffic Association, Inc.
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Density Group
(pcf)
Less than 8
8 but less than
12
12 or greater
200
One-Class
Adjustment for
Greatest
Dimension Not
Exceeding 96”
250
Two-Class
Adjustment for
Greatest
Dimension
Exceeding 96”
300
9.90 / 9.70
100
110
125
19.20 / 18.21
70
77.5
85
Average Density (pcf)
Greatest Dimension
Not Exceeding/
Exceeding 96’’
Class Based on
CCSB Density
Guidelines
4.84 / 4.36
Adding an attendant Note, as proposed, stating “Greatest dimension refers to the
longest straight-line dimension of the handling unit as tendered for shipment,” would be in
keeping with CCSB policies with respect to clarification.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policy and precedent.
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©2013 National Motor Freight Traffic Association, Inc.