Re: Pallets, Platforms or Skids, for lift trucks, plastic, with or without steel reinforcement

Transcription

1 Re: Pallets, Platforms or Skids, for lift trucks, plastic, with or without steel reinforcement CCSB Contact: Donald A. Newell Telephone (703) Proponent: Mercury Marine, Fond du Lac, Wisconsin Present Classification Provisions Item Description Class PALLETS GROUP: subject to item Pallets, Platforms or Skids, for lift trucks, including Spill Containment Pallets, see Note, item , plastic, other than cellular, expanded or foam plastic, with or without cellular, expanded or foam plastic core or steel reinforcement, without bodies, enclosures, ends, sides, standards or stacking posts, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 6 but less than Sub 3 10 or greater NOTE The term Spill Containment Pallets refers to pallets with an integral reservoir or receptacle to contain escaped material * Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, steel or wood, with or without bodies, enclosures, ends, sides, stakes, standards or stacking posts, see Note, item , subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater * NOTE Pallets, platforms, shipping racks or skids with set-up or standing bodies, enclosures, ends, sides, stakes, standards or stacking posts may be equipped with interior packing forms, trays or devices when contained within the pallets, platforms, shipping racks or skids which they are intended to equip. *Published in Supplement 2 to NMF 100-AM, issued on July 25, 2013 with an effective date of August 24, National Motor Freight Traffic Association, Inc. Subject 15, Page 1 of 5

2 Proposed Classification Provisions Item Description Class PALLETS GROUP: subject to item Pallets, Platforms or Skids, for lift trucks, including Spill Containment Pallets, see Note, item , plastic, other than cellular, expanded or foam plastic, with or without cellular, expanded or foam plastic core or steel reinforcement, without bodies, enclosures, ends, sides, standards or stacking posts, etc... Cancel; see item NOTE Cancel; see item NEW Pallets; Platforms; Racks, shipping, NOI; or Skids; for lift trucks, plastic, steel or wood, with or without bodies, enclosures, ends, sides, stakes, standards or stacking posts, see Notes, items and NEW, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 1 but less than Sub 3 2 but less than Sub 4 4 but less than Sub 5 6 but less than Sub 6 8 but less than Sub 7 10 but less than Sub 8 12 but less than Sub 9 15 but less than Sub but less than Sub or greater NOTE No Change. NEW NOTE Also applies on Spill Containment Pallets with integral reservoirs or receptacles to contain escaped materials. Analysis The proponent, Mercury Marine, believes that the currently applicable provisions for plastic pallets found in item are not appropriate for the plastic pallets they ship on a return basis to their parts suppliers. The proponent believes that with a density of 5.74 pcf the currently applicable class 200, per sub 1 of the item, is inappropriate. Their proposal would cancel item with reference to item , which presently applies on steel or wood pallets, and concurrently amend item to include plastic pallets, which, they believe, would provide for more appropriate class assignment. The proponent receives shipments of parts on these pallets and then returns the empty pallets back to the parts supplier in wrapped stacks of 18. They tender about 50 shipments of plastic pallets per year. All stacks are virtually identical. Subject 15, Page 2 of National Motor Freight Traffic Association, Inc.

3 History of Provisions The current provisions of item are the result of action taken on Docket , Subject 10 (October 2008). That proposal sought to amend item to provide classes based on density groups of less than 6 pcf, 6 but less than 10 pcf, and 10 pcf or greater. Information on that record revealed a range in density from 0.38 to pcf, with an average density of 6.07 pcf and almost 60% of the figures less than 6 pcf. No unusual or significant handling, stowability or liability considerations were observed. The proposal was approved as modified to include a reference to spill containment pallets, and the changes first appeared in Supplement 4 to NMF 100-AH, effective January 10, About Plastic Pallets Plastic lift truck skids, pallets or platforms hereinafter referred to as plastic pallets are used essentially the same as those made of wood, steel or other materials, i.e. to facilitate the transportation or storage of goods with the aid of a lift truck or pallet jack. Spill containment pallets have an integral reservoir or receptacle under the pallet deck to collect and hold materials that may be spilled from a container or containers loaded on the pallet. Examples of different plastic pallets, including spill containment types, are shown in the photos below National Motor Freight Traffic Association, Inc. Subject 15, Page 3 of 5

4 Transportation Characteristics Density Information on the current record includes data from the proponent, from CCSB dock surveys and from the CCSB Density Study 1 and consists of 5,161 density observations ranging from 0.18 to pcf. The average density has risen from 6.07 pcf in 2008 to 8.38 pcf today, and the densities are more evenly distributed throughout the range, as shown in the frequency distribution below. Frequency Distribution % of Figures in Interval 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% 22.61%23.39% 21.70% 13.74% 7.52% 6.99% 0.02% 0.83% 2.21% 0.33% 0.66% Density Intervals (pcf) Of the density figures of record, 1.41% exceed 20 pcf. Handling and Stowability Plastic pallets are usually shipped either bundled or wrapped in stacks as shown in the photo of one of the proponent s shipments at the right. There is no indication of any unusual or significant handling or stowability concerns. Liability In 2008, the average value per pound of plastic pallets was $1.33. The proponent indicates the value of their shipments of plastic pallets to be $2.37 per pound. The proponent states that they have experienced zero claims in the last year. There is no indication that there are any unusual or significant liability concerns with these products. 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. Subject 15, Page 4 of National Motor Freight Traffic Association, Inc.

5 Relationship to CCSB Policies and Guidelines CCSB policy calls for provisions to reflect a commodity s known transportation characteristics. Information of record shows plastic pallets range in density from 0.18 to pcf, with no unusual or significant handling, stowability or liability characteristics. The proponent asserts that item provides classes that are not appropriate for the transportation characteristics of plastic pallets. Accordingly, the proponent is seeking to cancel item and name plastic pallets in item , which names steel or wood pallets and assigns the CCSB s standard 11-subprovision full density scale that ranges from class 400 for densities of less than 1 pcf to class 60 for densities of 30 pcf or greater 2. CCSB policy states that commodities or commodity groups exhibiting a wide density range not accurately reflected by a single overall average density may be assigned densitybased classes; especially where there are no unusual or significant handling, stowability or liability characteristics and where there is no other feasible means of effectively narrowing the range. And where densities are distributed throughout the range, commodities or commodity groups may be assigned classes predicated on a full density scale. In this regard, CCSB policy states that the 11-subprovision density progression should generally be assigned when a substantial percentage of the densities involved exceeds 20 pcf. Otherwise, the CCSB s standard nine-subprovision full density scale should generally be assigned. Only 1.41% of the density observations of record for plastic pallets exceed 20 pcf. Consequently, analyzed by itself, the data for plastic pallets supports the CCSB s nine-subprovision density progression. However, CCSB policy also calls for combining descriptions embracing related commodities, in the interest of clarification and simplification. This proposal would classify plastic pallets with their steel or wood counterparts in item Moreover, the full-scale density provisions in item would also reflect the more-even distribution of densities now exhibited by plastic pallets, as compared to the density distribution when the current provisions of item were established in In this regard, the distribution of densities now exhibited by plastic pallets is similar albeit with a lesser percentage exceeding 20 pcf to that of steel or wood pallets when the density provisions in item were established 3. In consideration of all information of record, this proposal, as docketed, is consistent with CCSB policy and precedent. 2 The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. 3 Per Subject 10 of Docket (September 2012), which was approved as docketed, with the provisions first appearing in Supplement 4 to NMF 100-AL, effective December 1, National Motor Freight Traffic Association, Inc. Subject 15, Page 5 of 5