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From: Joel Ringer Sent: Thursday, February 18, 2016 10:53 AM To: Griffis, Robert <[email protected]> Cc: Anderson, Danny <[email protected]>; Reiland, Andy <[email protected]>; Wright, Theresa <[email protected]>; Matthew Erim <[email protected]> Subject: Request for Reconsideration - Subject 2 of Docket 2016-1 - Scaffolding or Scaffolds, or Components or Parts thereof Mr. Griffis, In requesting reconsideration of Docket 2016-1, Subject 2, you state that you agree with the approach taken by the CCSB in reclassifying Scaffolding or Scaffolds, or Components or Parts thereof, i.e. canceling the provisions under item 33460 and assigning classes based on greatest dimension and density. But you would like the CCSB to consider modifying the proposal by adding certain dimensional and density groupings, with classes assigned accordingly. In reviewing your request, we find that the modification you suggest would be beyond the scope of the proposal. In particular, the lowest class presently assigned to those articles named under item 33460 is 70, and the lowest class proposed is 70. Assignment of classes 55 and 65, as included in your modification, would, therefore, be beyond the scope. (Same is the case for the scaffold brackets presently named in item 93620, at class 70.) Assigning any class lower than 70 — or higher than 200 for that matter — cannot be accomplished on the record of Docket 2016-1, Subject 2. A new proposal would be necessary. In view of the foregoing, the CCSB has denied your request for reconsideration. Disposition Bulletin 1343, which provides the CCSB’s decision, is attached. A hard copy of the Disposition Bulletin is being mailed to you. We would be happy to work with you to develop a new proposal. That would give us an opportunity to address some questions and concerns we have with the provisions you’re suggesting, such as your reasoning for recommending a 72-inch demarcation, and the fact that assigning class 70 where densities are less than 15 pcf would not meet CCSB guidelines. If you would like to discuss this matter further, we would be pleased to do so. Feel free to call Matt Erim or me at your convenience. Regards, Joel L. Ringer Chairman Commodity Classification Standards Board 1001 North Fairfax Street, Suite 600 Alexandria, Virginia 22314 703.838.1826 [email protected]
From: Joel Ringer Sent: Tuesday, February 16, 2016 10:53 AM To: Griffis, Robert <[email protected]> Cc: Anderson, Danny <[email protected]>; Reiland, Andy <[email protected]>; Wright, Theresa <[email protected]> Subject: RE: Request for Reconsideration, Subject 2 - Docket 2016-1 Scaffolding or Scaffolds, or Components or Parts Thereof Mr. Griffis, We have received your request for reconsideration of the CCSB’s disposition of Docket 2016-1, Subject 2, involving Scaffolding or Scaffolds, or Components or Parts thereof. The CCSB will consider your request in accordance with our procedures, and you will be notified of the decision. Regards, Joel L. Ringer Chairman Commodity Classification Standards Board 1001 North Fairfax Street, Suite 600 Alexandria, Virginia 22314 703.838.1826 [email protected] From: Griffis, Robert Sent: Monday, February 15, 2016 5:04 PM To: '[email protected]' Cc: Anderson, Danny; Reiland, Andy; Wright, Theresa Subject: Request for Reconsideration, Subject 2 - Docket 2016-1 Scaffolding or Scaffolds, or Components or Parts Thereof Mr. Ringer, As the Transportation Manager for the largest provider of Scaffolding and Access Solutions in North America, Safway Group Holdings LLC, I have concerns about the pending changes in the classification of our product. With 115 locations in North America, providing scaffolding solutions for the petrochemical, oil and gas, power, refining, marine, manufacturing, transportation and commercial construction industries, Safway moves over 20,000 LTL shipments via Common Carrier each year. I am requesting reconsideration of the recommended changes in Subject 2 – Docket 2016-1 for scaffolding products. As an LTL shipper, I believe that classification by dimension and density is the most equitable solution for classification of products shipped via Common Carrier. In 2005, I proposed, and had approved, a reclassification of the Stationery Group 179180 from a flat class 100 to a full density Group, Stationery Sets 179180, class 60 to 400. My company at that time shipped stationery sets ranging in densities from 4pcf to 30pcf, but 70% of the stationery sets were greater than 22.5pcf at class 65. My concerns with the suggested changes to the scaffolding classification are similar, in that 85% of the parts that Safway currently has in stock are less than 8 feet in length, and the current recommendation does not account for the volume and densities of the majority of the product that we ship.
I am in agreement with the elimination of NMFC Item 33460 Builders’ or Maintenance Horses, Scaffolds, Scaffolding, or Scaffold Sections. I am also in agreement with the classification of NMFC Item 172521 Scaffolding or Scaffolds, by length, in Sub Groups 1 through 9. I would suggest adding, however, the following new Sub Groups: Under “Greatest dimension exceeding 192 inches” amend “having a density in pounds per cubic foot of: 15 or greater, class 100” to “greater than 15 but less than 30, class 100” and add “30 or greater, class 85”. Under “Greatest dimension exceeding 96 inches but not exceeding 192 inches” amend “having a density in pounds per cubic foot of: 15 or greater, class 85” to “greater than 15 but less than 30, class 85” and add “30 or greater, class 70”. Amend “Greatest dimension not exceeding 96 inches” to “Greatest dimension exceeding 72 inches but not exceeding 96 inches”, and amend “having a density in pounds per cubic foot of: 15 or greater, class 70” to “greater than 15 but less than 30, class 70” and add “30 or greater, class 65”. Add the following new Sub Groups: “Greatest dimension not exceeding 72 inches having a density in pounds per cubic foot of: less than 15, class 70, greater than 15 but less than 30, class 65, greater than 30, class 55”. Attached is supporting documentation showing that 85% of current Safway parts in stock are less than 8 feet in length, and that only 15% of our LTL shipments over the last six months have incurred over-dimensional fees from the LTL carriers. Also attached are documents picturing our method of racking and stacking freight, with dimensions and densities noted on many of our products. Note that densities are many times well over 30pcf, while we do have lightweight products of aluminum, or bulky steel products with lower densities. I will also include in a separate email, a pictorial tour of our Milwaukee, Wisconsin Branch, illustrating that over half of the racks in the yard and warehouse contain product that is less in length than 8 feet. These racks are easy for LTL carriers to load and unload, are stackable, and when the product is less than 8 feet, these racks are just as easy to load and stow as any other palletized freight. Classification by dimension and density is the most equitable solution for classification of products shipped via Common Carrier. We simply require that the new recommendation allows for the proper classification of all scaffolding, without assuming that all scaffolding is “lengthy freight”. As illustrated in the attachments, Safway Scaffolding ships in all shapes and sizes, and the new classification needs to allow for all shapes, sizes, and densities. Thank you for your careful consideration,
Robert Griffis
Transportation Manager
Safway Group Holding LLC
N19 W24200 Riverwood Drive
Waukesha, WI 53188
P: (262) 523-6565
C: (262) 443-4579
