CCSB DOCKET 2017-2
SECTION I
SUBJECT 1
Re: Pipe, Tubing, or Pipe or Tubing Fittings, aluminum, including Aluminum Electrical Conduits
CCSB Contact: Erin N. Topper
Telephone — (703) 838-8856
[email protected]
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
Description
Class
CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item 50750
50940
Conduits, electrical, aluminum, in straight lengths not exceeding 10 feet,
inside diameter not exceeding 6 inches, with a wall thickness 0.0907
inch or thicker, threaded ends protected, with or without couplings
or ferrules, see Notes, items 50942 and 518221, in packages ................. 70
50942
NOTE—Also applies on conduit in bent shapes not in excess of 10 percent of
the weight on which charges are assessed.
52175*
Pipe, Tubing, or Pipe or Tubing Fittings, aluminum, combined or not
combined with other materials, NOI, in packages:
Sub 1
Greatest dimension exceeding 192 inches .................................................. 100
Sub 2
Greatest dimension exceeding 96 inches but not exceeding 192 inches. 85
Sub 3
Greatest dimension not exceeding 96 inches ............................................... 70
*Published in Supplement 1 to NMF 100-AQ, effective April 15, 2017.
Proposed Classification Provisions
Item
50940
50942
Description
Class
CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item 50750
Conduits, electrical, aluminum, in straight lengths not exceeding 10 feet,
inside diameter not exceeding 6 inches, with a wall thickness
0.0907 inch or thicker, threaded ends protected, with or
without couplings or ferrules, etc .............................................. Cancel; see
item 52175
NOTE—Cancel; no further application.
Note, item 51822, which read “Detached couplings, ferrules, valves or nipples must be in bags, boxes
or drums,” was canceled effective April 15, 2017 by action taken on Subject 6 of Docket 2017-1
(January 2017).
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©2017 National Motor Freight Traffic Association, Inc.
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Proposed Classification Provisions — Concluded
Item
Description
Class
CONDUITS, OTHER THAN EARTHEN, GROUP: subject to item 50750
52175
Pipe, Tubing, or Pipe or Tubing Fittings, aluminum, combined or not
combined with other materials, NOI, in packages:
Sub 1
Greatest dimension exceeding 288 inches, subject to Item 170 and
having a density in pounds per cubic foot of:
Sub 2
Less than 15 ................................................................................................. 250
Sub 3
15 or greater ................................................................................................ 100
Sub 4
Greatest dimension exceeding 192 inches but not exceeding 288
inches, subject to Item 170 and having a density in pounds
per cubic foot of:
Sub 5
Less than 15 ................................................................................................. 200
Sub 6
15 or greater .................................................................................................. 92.5
Sub 7
Greatest dimension exceeding 96 inches but not exceeding 192 inches,
subject to Item 170 and having a density in pounds per cubic
foot of:
Sub 8
Less than 15 ................................................................................................. 125
Sub 9
15 or greater .................................................................................................. 77.5
Sub 10
Greatest dimension not exceeding 96 inches, subject to Item 170 and
having a density in pounds per cubic foot of:
Sub 11
Less than 15 ................................................................................................. 110
Sub 12
15 or greater .................................................................................................. 65
Analysis
Background of Proposal
This proposal is based on the continuation of Research Project 1282 on aluminum pipe,
tubing, or pipe or tubing fittings. The project was initiated in June of 2016 in response to reports
of densities inconsistent with the then-assigned classes.
Docket 2017-1, Subject 6 (January 2017) was a proposal based on the information
developed through the project. As a result of action taken on that docket, new item 52175
was established, with classes predicated on greatest dimension. During the January 2017
CCSB meeting at which the proposal was considered, persons in attendance questioned
whether the classes in the new item should be further delineated by density, in addition to
greatest dimension.
Since the last docket, it was found that Note, item 51822, which was canceled as of
April 15, 2017 as a result of action taken on that proposal, is referenced by item 50940. Item
50940 applies on a very specific type of aluminum electrical conduit. The provisions of item
50940 were established as a result of action taken on Docket 831, Subject 22 (January 1983),
which was a shipper proposal to add a new item for their products. Information from that
record indicates the proponent’s densities ranged from 32.5 to 70.46 pcf, with an average of
44.16 pcf. A competitor’s products ranged in density from 24.3 to 60 pcf, with an average of
Subject 1, Page 2 of 6
©2017 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2017-2
SECTION I
SUBJECT 1
39.06 pcf. The value of the proponent’s products was $1.00 per pound (in 1983 dollars). There
was no indication of any negative handling, stowing or liability considerations. The proposal
was approved as modified, and the provisions first appeared in Supplement 5 to NMF 100-J,
effective August 13, 1983. The provisions have remained substantially unchanged to the
present.
Due to the similar nature of these products and the aluminum pipe or tubing evaluated
on the last docket, data for shipments moving under item 50940 has been incorporated into
this record.
Transportation Characteristics
Density—The information of record includes 19,102 density figures observed firsthand on a
CCSB dock survey and obtained through the CCSB’s Density Study2. The densities range from
0.60 to 70.61 pcf, with an overall average of 17.61 pcf. When the data is evaluated based on
greatest dimension, where known, and a density break at 15 pcf, the following density ranges
and averages are found.
Greatest Dimension
Exceeding 288 inches
Greatest Dimension
Exceeding 192 inches but not
exceeding 288 inches
Greatest Dimension
Exceeding 96 inches but not
exceeding 192 inches
Greatest Dimension
Not exceeding 96 inches
Density Group
(pcf)
Less than 15
15 or greater
Density Range
(pcf)
2.46 – 14.88
15.07 – 70.50
Average Density
(pcf)
10.24
31.21
Density Group
(pcf)
Less than 15
15 or greater
Density Range
(pcf)
1.10 – 14.98
15.00 – 69.92
Average Density
(pcf)
8.68
29.25
Density Group
(pcf)
Less than 15
15 or greater
Density Range
(pcf)
1.16 – 14.96
15.00 – 70.59
Average Density
(pcf)
9.08
27.27
Density Group
(pcf)
Less than 15
15 or greater
Density Range
(pcf)
1.10 – 14.98
15.00 – 70.00
Average Density
(pcf)
8.06
28.60
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.
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©2017 National Motor Freight Traffic Association, Inc.
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SECTION I
SUBJECT 1
Handling—The aluminum pipe, tubing and fittings of record vary greatly in size, with reported
lengths up to 360 inches (30 feet) and an average length of approximately 14 feet. As the
length increases, the handling into and out of the vehicle becomes considerably more
difficult, and certain equipment, or additional personnel, may be necessary to safely handle
long shipments. Furthermore, as the length increases, cross-dock operations can be
significantly affected. Often there is not enough room at carrier facilities to safely or easily
handle and maneuver excessively long pipe or tubing.
When secured to a lift truck skid or pallet the freight may be handled more readily with
mechanical equipment, since there is clearance for the fork tines to get under and lift them.
However, when the length exceeds 96 inches, even palletized shipments can be difficult to
safely handle with mechanical equipment. The level of difficulty increases as the length of the
article increases, even if fork extensions are available and used. Pipe or tubing tendered in
bundles require extra care and attention during handling, as there is often no clearance under
the bundle for fork tines.
Stowability—Fittings and shorter lengths of pipe or
tubing may be tendered in boxes, often unitized on
lift truck skids or pallets, while longer pieces may be
tendered in boxes, bundles or crates. When
tendered in boxes or crates the shipments generally
provide a flat load-bearing surface.
Excessively long pipe or tubing tendered in
boxes, bundles or crates may be difficult to stow with
other general freight and will typically require floor
loading. When floor loaded, it may be difficult to
stow adjacent freight, and those tendered in bundles do not provide a flat load-bearing
surface, which reduces or complicates the carrier’s ability to load freight on top and maximize
vehicle utilization. Depending on the length of the package or handling unit, the carrier will
have to ensure that the freight will fit in the vehicle.
Liability—Pipe, tubing or fittings may damage other freight if not stowed properly within the
vehicle and may be at risk for some damage from handling, particularly when the greatest
dimension exceeds 96 inches. In this regard, the Note, item 50752 requires pipe, tubing and
fittings having surfaces liable to damage to be in boxes, crates or fiberboard tubes or to be
completely wrapped in material sufficient to prevent abrasion, marring or denting during
transit. The Note also requires threaded or machined ends liable to damage to be protected
with plugs or caps. One carrier reported a claims ratio of 0.35% for aluminum pipe or tubing,
NOI, moving under former item 51820. No value information on the involved articles was
obtained.
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©2017 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2017-2
SECTION I
SUBJECT 1
Relationship to CCSB Policies and Guidelines
CCSB policies state that provisions that are a source, or potential source, of
interpretation disputes should be amended, and classifications embracing related
commodities should be combined. For these reasons, it would be in keeping with CCSB policy,
as proposed, to cancel item 50940 with reference to item 52175 to combine provisions
applying on similar commodities and to mitigate the chance of interpretation issues. The Note,
item 50942 would be concurrently canceled with no further application.
CCSB policies also state that classifications should reflect a commodity’s known
transportation characteristics. The information of record includes 19,102 density observations,
which average 17.61 pcf, with a range from 0.60 to 70.61 pcf. Under CCSB guidelines, an
average density of 17.61 pcf would generally call for class 70, absent any negative handling,
stowing and liability considerations. However, as discussed in this analysis, pipe, tubing and
pipe or tubing fittings exhibit significant negative handling, stowing and liability considerations.
Specifically, it was found that greatest dimension has the most considerable effect on the
transportability of these products, and as greatest dimension increases the issues increase
exponentially.
Due to the range of densities exhibited within each of the greatest dimension
delineations, the tables below identify the resulting average densities, classes based on CCSB
density guidelines and the proposed classes when the data is evaluated based on greatest
dimension (in eight-foot increments) and a density break at 15 pcf.
Greatest Dimension
Exceeding 288 inches
Greatest Dimension
Density Group
(pcf)
Less than 15
15 or greater
Average
Density (pcf)
10.24
31.21
Guideline
Class
100
60
Class
Adjustment
Density Group
(pcf)
Average
Density (pcf)
Guideline
Class
Class
Adjustment
Less than 15
8.68
110
200
15 or greater
29.25
65
92.5
Density Group
(pcf)
Average
Density (pcf)
Guideline
Class
Class
Adjustment
Less than 15
9.08
100
125
15 or greater
27.27
65
77.5
Exceeding 192 inches but
not exceeding 288
inches
Greatest Dimension
Exceeding 96 inches but
not exceeding 192
inches
Greatest Dimension
Not exceeding 96 inches
Density Group
(pcf)
Less than 15
15 or greater
Average Density
(pcf)
8.06
28.60
©2017 National Motor Freight Traffic Association, Inc.
250
100
Guideline and
Proposed Class
110
65
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Based on the information of record, as greatest dimension increases, the more difficult
the pipe, tubing, or pipe or tubing fittings are to handle and stow. The proposed classes
account for the increasingly less-than-favorable handling, stowing as well as liability
characteristics. The class assignments to pipe, tubing and fittings having greatest dimension
exceeding 96 inches—in respective eight-foot increments—reflect the increasingly significant
handling, stowing and liability problems associated with those articles. In this regard, an
additional greatest dimension delineation at 288 inches would be added to item 52175 in view
of reported lengths of up to 360 inches.
This proposal is also in keeping with CCSB precedent. As a result of action taken on
Subject 1 of Docket 2017-1 (January 2017), new item 108775, applying on ladders or
stepladders, NOI, was established with classes predicated on greatest dimension and density.
That proposal was approved as docketed, and the provisions first appeared in Supplement 1
to NMF 100-AQ, effective April 15, 2017.
Based on the information of record, this proposal, as docketed, is in keeping with CCSB
policies and precedent.
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©2017 National Motor Freight Traffic Association, Inc.