Re: Shakes or Shingles, including Shake or Shingle Panels or Corners, wood

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1 Re: Shakes or Shingles, including Shake or Shingle Panels or Corners, wood CCSB Contact: George M. Beck Telephone (703) Shannon C. Allard (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Panels, siding, wood shingles backed with paper and insulation board, in packages LUMBER GROUP: subject to item Shingles, wooden, whether or not creosoted or otherwise preservatively treated, in packages Shingles, wooden, in multiples of two or more backed with wooden sheathing, with or without water-proofed paper, in boxes or crates, see Note, item NOTE Each package may include nails necessary for erection not to exceed 2 percent of weight upon which charges are assessed. Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Panels, siding, wood shingles backed with paper and insulation board, etc... Cancel; see LUMBER GROUP: subject to item Shingles, wooden, whether or not creosoted or otherwise preservatively treated, etc... Cancel; see Shingles, wooden, in multiples of two or more backed with wooden sheathing, with or without water-proofed paper, etc... Cancel; see NOTE Cancel; no further application. ROOFING OR SIDING MATERIALS GROUP: subject to item NEW Shakes or Shingles, including Shake or Shingle Panels or Corners, wood, with or without components of other materials, in packages National Motor Freight Traffic Association, Inc. Subject 7, Page 1 of 5

2 Analysis Research Project 1189 This proposal is based on information developed through Research Project 1189, which was initiated in July of 2013 in response to interpretative issues involving shingle panels or corners, and to investigate the transportation characteristics of wood shakes or shingles and shake or shingle panels or corners. Hereinafter, these products will be referred to as wood shakes or shingles. During the course of Research Project 1189, questionnaires were mailed to 109 potential manufacturers or shippers and 11 trade associations in July of 2013, and again to those that did not respond, in September of 2013, inviting them to participate in the research. From this sampling, seven questionnaires were returned as undeliverable, seven companies responded that they did not manufacture or ship the involved articles, and three companies provided usable information. Regarding the 11 trade associations contacted, two responded that they did not represent manufacturers or shippers of the involved articles. No response was received from the remaining associations. History of Provisions Item first appeared in Supplement 5 to NMFC No. 5, effective July 15, The establishing docket file could not be located. The current class 70 was the result of action taken on Special Docket No. 1 (issued July 20, 1949) and first appeared in NMFC A-1, effective July 10, The provisions have remained substantially unchanged to the present. The basic provisions of item were adopted from the rails and first appeared in LTL-1, effective April 1, 1936 at a rating equivalent to the current class 50. As a result of action taken on Special Docket No. 1 (issued July 20, 1949), the provisions were amended to include whether or not creosoted or otherwise preservatively treated. This change first appeared in NMFC A-1, effective July 10, 1952, and the provisions have remained substantially unchanged to the present. Item and Note, item , were established as a result of action taken on Special Docket No. 2 (issued April 27, 1951). These provisions first appeared in NMFC A-1, effective July 10, 1952 and have remained substantially unchanged to the present. Subject 7, Page 2 of National Motor Freight Traffic Association, Inc.

3 About Wood Shakes or Shingles The information of record encompasses a variety of wood shakes or shingles. The involved articles are pieces of wood, which are primarily used to cover roofs or exterior walls of houses or other buildings. Wood shakes or shingles are available in varying designs and configurations. Examples of the involved articles are shown in the photos below. Transportation Characteristics Density The information of record includes 551 density observations submitted by shippers and carriers, and obtained from the CCSB Density Study 1. The products range in density from 3.20 to pcf, with an average density of pcf. The frequency distribution for wood shakes or shingles is presented on the following page. 1 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 National Motor Freight Traffic Association, Inc. Subject 7, Page 3 of 5

4 Frequency Distribution % of Figures in Interval 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% 42.65% 13.25% 17.24%15.43% 0.00% 0.00% 0.36% 1.81% 1.45% 3.45% 4.36% Density Intervals (pcf) As the above frequency distribution depicts, the greatest concentration of figures slightly above 73% are clustered between 12 and 30 pcf, with over 42% of the figures within the 15 but less than 22.5 pcf interval. Handling and Stowability The information of record indicates that the involved articles are generally tendered for shipment banded or wrapped on lift truck skids or pallets, or in fiberboard boxes, which may be secured on lift truck skids or pallets. There have been no reports of unusual or significant handling or stowability problems. Liability Wood shakes or shingles are not perishable, prone to spontaneous combustion or explosion, unusually susceptible to theft, unusually liable to damage, and would not appear likely to damage other freight. One carrier reported a claims ratio of 2.10% for product shipments moving under item , while another reported no claims for the involved articles. Responding shippers reported minimal to no claims for the involved articles. Value per pound ranges from $0.08 to $2.98, with an average value of $1.17 per pound. Subject 7, Page 4 of National Motor Freight Traffic Association, Inc.

5 Relationship to CCSB Policies and Guidelines CCSB policy calls for the establishment or amendment of classifications for commodities that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. The CCSB has received interpretation inquiries regarding the applicable provisions for wood shingle panels or corners. Through research, it has been determined that the applicable provisions for the involved commodities are found within items 35070, and ; however, the current language of the provisions is believed to be unclear, which has resulted in confusion. As such, to address the interpretation issues, and in the interest of clarification and simplification, it would be within CCSB policy to combine these related provisions and more clearly name the involved commodities. Under this proposal, the provisions of items 35070, and would be canceled with reference to a new item under the Roofing or Siding Materials Group for Shakes or Shingles, including Shake or Shingle Panels or Corners, wood, with or without components of other materials. Furthermore, Note, item would be canceled with no further application. CCSB policy also calls for provisions to reflect a commodity s known transportation characteristics. Information of record for wood shakes or shingles shows a range in density from 3.20 to pcf, with an average density of pcf, and no unusual or significant handling, stowability or liability characteristics. As shown in the frequency distribution on page 4, the preponderance of density figures are concentrated within a narrow range around the overall average. Under CCSB guidelines, an average density of pcf is generally associated with a class 70, which calls for a minimum average density of 15 pcf. This proposal would assign class 70 to the new item. A similar approach was taken on Docket , Subject 6 (September 2013), involving earphones, headphones or headsets. No significant handling, stowability or liability concerns were reported, and, as such, density was determined to be the primary transportation characteristic. As with wood shakes or shingles, earphones, headphones or headsets exhibited a wide range of densities from 1.90 to pcf with a significant concentration of density observations over 88% clustered around the overall average density of 5.64 pcf. Based on the information of record, and in keeping with CCSB guidelines, that proposal was approved as docketed, assigning class 175, and the provisions first appeared in Supplement 4 to NMF 100-AM, effective December 14, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent National Motor Freight Traffic Association, Inc. Subject 7, Page 5 of 5

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