CCSB Contact: Lisa K. O Donnell Telephone (703) Item Description Class

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1 Re: Interior Shades, Shutters or Blinds CCSB Contact: Lisa K. O Donnell Telephone (703) odonnell@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item NOTE Not Involved Doors, Partitions or Shutters, rolling, wooden, see Note, item 34282, in packages Shutters; or Foundation Ventilators (Sash and Screen combined); plastic, with or without components of other materials, in boxes, 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 SHADES OR BLINDS GROUP: subject to item Shades or Blinds, interior, including Venetian Blinds, Mini-Blinds or Vertical Blinds; or Wood Shutters, interior; in boxes or crates: Sub 1 Greatest dimension exceeding 192 inches Sub 2 Greatest dimension exceeding 96 inches but not exceeding 192 inches Sub 3 Greatest dimension not exceeding 96 inches National Motor Freight Traffic Association, Inc. Subject 6, Page 1 of 8

2 Proposed Classification Provisions Item Description Class BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item NOTE No Change Doors, Partitions or Exterior Shutters, rolling, wooden, etc... No Change Shutters, exterior; or Foundation Ventilators (Sash and Screen combined); plastic, with or without components of other materials, in boxes, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Subs 1-11 No Change. SHADES OR BLINDS GROUP: subject to item Shades, Shutters or Blinds, interior, including Venetian Blinds, Mini-Blinds or Sub 1 Vertical Blinds, in boxes or crates: Greatest dimension exceeding 192 inches, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 4 but less than Sub 4 8 or greater Sub 5 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 6 Less than Sub 7 4 but less than Sub 8 8 or greater Sub 9 Greatest dimension not exceeding 96 inches, subject to Item 170 and having a density in pounds per cubic foot of: Sub 10 Less than Sub 11 4 but less than Sub 12 8 or greater Analysis Research Project 1290 This proposal is based on the information developed through Research Project 1290, which was initiated in September 2016 to research the transportation characteristics of interior shutters. During the course of research, it was determined that the distinction between interior shutters and blinds is sometimes unclear, which could lead to interpretation problems 1. As such, the CCSB expanded Research Project 1290 to include interior shades and blinds, per item This is made evident by a description on a website specializing in window coverings that reads: shutters are commonly known as a variation of stationary blinds that come with a rod. See: (accessed August 14, 2018) Subject 6, Page 2 of National Motor Freight Traffic Association, Inc.

3 Interior shutters are classified according to their material construction and manner in which they open and close (i.e., rolling versus louver) in items 34500, or All interior shades or blinds are classified in item History of Provisions The provisions for wooden doors, partitions or shutters, rolling, in current item 34500, were adopted from the rail classification and first appeared in LTL-1, effective April 1, 1936, at a rating equivalent to the current class 70. The provisions have remained substantially unchanged to the present. Item was established as a result of action taken on Docket 772, Subject 30 (March 1977) to provide a new item for plastic shutters at class 100. The provisions first appeared in Supplement 14 to NMF 100-D, effective October 22, As a result of action taken on Docket 805, Subject 76 (July 1980), item was amended to provide densitybased classes with the then-standard nine-subprovision density scale. The changes first appeared in Supplement 19 to NMF 100-G, effective February 28, As a result of action taken on Docket 913, Subject 8 (May 1991), plastic foundation ventilators (sash and screen combined) were added to the provisions of item This change first appeared in Supplement 2 to NMF 100-R, effective June 29, As a result of action taken on Docket , Subject 16 (May 2017), the current 11-subprovision density scale was established. The changes first appeared in Supplement 2 to NMF 100-AQ, effective August 5, The provisions have remained unchanged to the present. Provisions applying on interior shades or blinds were adopted from the rails in Since that time, numerous proposals have established and/or amended various provisions applying on shades or blinds of different type, material construction and/or assembly. As a result of action taken on Subject 1 of Docket (May 2003), the provisions of several items applying on interior shades or blinds were canceled with reference to item Concurrently, the generic heading reading Shades, With or Without Fixtures was revised to read Shades or Blinds Group, and all provisions related to shades or blinds were relocated under that generic heading. That proposal was approved as docketed, and the changes first appeared in Supplement 5 to NMF 100-AC, effective July 26, As a result of action taken on Docket , Subject 14 (June 2008), the language or Wood Shutters, interior was added to the description of item for clarification, and the provisions first appeared in Supplement 2 to NMF 100-AH, effective August 23, As a result of action taken on Docket , Subject 2 (September 2016), item was amended to adjust the greatest dimension delineations and respective classes to those currently provided in the item. The changes first appeared in Supplement 4 to NMF 100-AP, effective December 10, The provisions have remained unchanged to the present National Motor Freight Traffic Association, Inc. Subject 6, Page 3 of 8

4 About Interior Shades, Shutters or Blinds Interior shades, shutters or blinds are designed to cover windows to provide privacy and control the outdoor light entering a building 2. Product literature on these three variations of window coverings indicates that the term blinds is sometimes used to describe shades or shutters. Furthermore, interior wood shutters are named in item ; whereas faux wood interior shutters made of plastic are classified in item It is difficult to discern wood from plastic shutters as they are marketed to have the look and feel of real hardwood 3. These factors may lead to interpretation questions as to the applicable item. Photographs of the involved products are shown below. Shades Shutters Blinds Transportation Characteristics Density The information of record for interior shades, shutters or blinds includes 96,842 density observations submitted by shippers and a carrier, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 4. The products range in density from 0.05 to pcf, with an overall average of 7.63 pcf. When the data is evaluated based on greatest dimension, where known 5, and density breaks at 4 and 8 pcf, the density ranges and averages in the tables on the following page emerge. 2 A shade is usually made of fabric attached to a spring roller, which may be positioned up or down by pulling on the bottom or top of the shade. Blinds are made of a variety of materials, including plastic, aluminum or wood, with slats or vanes that can be opened or closed with a cord or a wand to vary the light entering the room. Shutters are typically a solid covering made of wood or plastic, often with slats that can be opened and closed to vary the light entering the room. See: (accessed August 7, 2018) 3 See (accessed November 7, 2018) 4 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. 5 Some of the data derived from the Density Study contains information on the cube and the weight of the articles, not the dimensions and weight. Subject 6, Page 4 of National Motor Freight Traffic Association, Inc.

5 Greatest Dimension Exceeding 192 inches Exceeding 96 inches but not exceeding 192 inches Not exceeding 96 inches Density Group Density Range (pcf) (pcf) Average Density (pcf) Less than but less than or greater Less than but less than or greater Less than but less than or greater Handling Interior shades, shutters or blinds are typically tendered in fiberboard boxes. When not exceeding 96 inches in greatest dimension, most shades, shutters or blinds are shipped in boxes secured on lift truck skids or pallets. The photo to the right is a shipment of wood shutters in a fiberboard box measuring 82 x 32 x inches. Although some shipments include the precautionary markings and shipper instructions Fragile and Handle with Care, handling units not exceeding 96 inches in length generally do not pose any unusual or significant handling problems. However, shades, shutters or blinds vary greatly in size, with reported lengths up to 316 inches (26.33 feet) and an average length of inches (9.93 feet) 6. As the length/size increases, the handling into and out of the vehicle becomes considerably more difficult, and special equipment, or additional personnel, may be necessary to safely handle long handling units. 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 units. The photo to the left shows a shipment of interior blinds being moved manually from one area of a carrier dock to another by means of a hand truck with an extended platform. The longest box shown measured 168 x 5.00 x 8.25 inches and substantially overhung the carrier s handling equipment. As demonstrated, handling the longer units is more difficult than handling general boxed freight. 6 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 freight becomes more difficult to load and unload when compared to general freight National Motor Freight Traffic Association, Inc. Subject 6, Page 5 of 8

6 Stowability Shades, shutters or blinds not exceeding 96 inches in length typically do not present significant negative stowability considerations, although some shipments include the shipper instructions Top Load Only or Do Not Double Stack. Excessively long handling units may be difficult to stow with other general freight, particularly as they may lack a flat loadbearing surface for top freight. The photos below demonstrate that, even if a flat load-bearing surface is available for other freight, it can be difficult for the carrier to make efficient use of remaining vehicle space due to the relatively narrow width of shades, shutters or blinds as packaged for shipment. Carrier personnel may have to take extra time and effort to ensure that a vehicle load is configured appropriately to accommodate shipments containing extralong shades, shutters or blinds. Liability The involved commodities are not perishable, unusually susceptible to theft, hazardous in nature, nor do they appear likely to damage other freight. However, as the greatest dimension of the handling unit increases, shades, shutters or blinds may be more prone to damage as they have a greater propensity to bend or be crushed at the ends in handling or in transit. A shipper reported seven claims per year 7. Carriers reported no claims information for the involved articles. The value per pound for shutters or blinds ranges from $2.67 to $17.65, with an average of $9.21 per pound 8. Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to be as clear as possible to help preclude interpretation disputes and also calls for combining descriptions for related commodities. As discussed in this proposal, there are interpretation issues related to shutters being referred to as blinds, and plastic faux wood shutters being confused with wood shutters. To mitigate these interpretation issues, this proposal, in keeping with CCSB policy, would revise the provisions of items and to restrict their application to exterior shutters. It would concurrently amend item to remove the material construction restriction of wood to the listing for shutters. 7 The shipper claimed to represent 5% of the market share of interior shutters. 8 No value information was received on shades. Subject 6, Page 6 of National Motor Freight Traffic Association, Inc.

7 CCSB policies state that classifications should reflect a commodity s known transportation characteristics. The information of record for interior shades, shutters or blinds shows a density range from 0.05 to pcf, with an overall average of 7.63 pcf. Under CCSB guidelines, an average density of 7.63 pcf is generally associated with class 125, which calls for a minimum average density of 7 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. Moreover, in this instance, research has identified several negative handling, stowability and liability issues that must also be considered, in accordance with CCSB policies. As the greatest dimension of the handling unit increases, shades, shutters or blinds have been found to be increasingly more difficult to handle and stow and may be more prone to damage. These factors have been detailed in this analysis. Accordingly, this proposal would establish classes predicated on greatest dimension and density breaks at 4 and 8 pcf 9. Based on the identified handling, stowing and liability concerns, which are amplified as the handling unit s greatest dimension increases, assigning classes higher than those provided by the CCSB density guidelines when the handling unit exceeds 96 inches would be consistent with CCSB policy. This proposal would establish provisions for shades, shutters or blinds with respective class adjustments for handling units exceeding 96 inches but not exceeding 192 inches, and exceeding 192 inches in greatest dimension. As described in the analysis, shades, shutters or blinds with a greatest dimension not exceeding 96 inches do not pose the same degree of unfavorable handling, stowability or liability characteristics as shades, shutters or blinds with greater dimensions. The associated average densities, guideline classes and proposed classes are depicted in the tables below. Greatest Dimension Exceeding 192 inches Exceeding 96 inches but not exceeding 192 inches Not exceeding 96 inches Density Group (pcf) Average Density (pcf) Guideline Class Class Adjustment Less than but less than or greater Less than but less than or greater Less than N/A 4 but less than N/A 8 or greater N/A 9 The density provisions would include reference to Item (Rule) 170, the inadvertence clause National Motor Freight Traffic Association, Inc. Subject 6, Page 7 of 8

8 This approach is in keeping with CCSB precedent. As a result of action taken on Docket , Subject 7 (January 2017), the provisions applying on carpets or carpeting, per item 70680, with classes based on greatest dimension and density of the handling unit, were amended. Due to the respective negative handling and stowing characteristics, class adjustments were assigned as handling units increased in greatest dimension. That proposal was approved as modified 10, and the provisions first appeared in Supplement 1 to NMF 100- AQ, effective April 15, Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. 10 Reflective of information received after the proposal was docketed, a class 175 rather than the proposed class 250 was assigned to carpets or carpeting with greatest dimension exceeding 192 inches and having a density of less than 12 pcf. Subject 6, Page 8 of National Motor Freight Traffic Association, Inc.