CCSB DOCKET 2012-1
SECTION I
SUBJECT 14
Re: Lamps, artificial sunlight, heating or therapeutic
Staff Contact: Daniel E. Horning
Telephone — (703) 838-1820
horning@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
Description
Class
LAMPS OR LIGHTING GROUP: subject to item 109000
109460
Lamps, artificial sunlight, heat ray or therapeutic, electric, with or without
electric incandescent lamps, in boxes or crates .................................. 125
109700
Lamps or Lighting Fixtures, see Notes, items 109701, 109702, 109703 and
109704, viz.:
Floor Standing Lamps, with or without integral tray, also in Package 817;
Lamps, NOI, also in Packages 794, 817, 1424, 1467, 2204 or 5F;
Lighting Fixtures, NOI;
[Other Articles Listed—Not Involved.]
In boxes or crates, subject to Items 170 and 171 and having a density
in pounds per cubic foot of, see Note, item 109706:
Sub 1
Less than 1 .......................................................................................... 400
Sub 2
1 but less than 2 .................................................................................. 300
Sub 3
2 but less than 4 .................................................................................. 250
Sub 4
4 but less than 6 .................................................................................. 150
Sub 5
6 but less than 8 .................................................................................. 125
Sub 6
8 but less than 10 ................................................................................ 100
Sub 7
10 but less than 12 ................................................................................ 92.5
Sub 8
12 but less than 15 ................................................................................ 85
Sub 9
15 but less than 22.5 ............................................................................. 70
Sub 10
22.5 but less than 30 ............................................................................. 65
Sub 11
30 or greater ......................................................................................... 60
109701
NOTE—One lamp (bulb) for each socket may be included in same box with
lamp or lighting fixture.
109702
NOTE—Not Involved.
109703
NOTE—Not Involved.
109704
NOTE—Not Involved.
109705
NOTE—Not Involved.
109706
NOTE—Not Involved.
©2011 National Motor Freight Traffic Association, Inc.
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SUBJECT 14
Proposed Classification Provisions
Item
Description
Class
LAMPS OR LIGHTING GROUP: subject to item 109000
109460
Lamps, artificial sunlight, etc ............................................................... Cancel; see
item 109700
109700
Lamps or Lighting Fixtures, see Notes, items 109701, 109702, 109703 and
109704, viz.:
Floor Standing Lamps, with or without integral tray, also in Package 817;
Lamps, artificial sunlight, heating or therapeutic;
Lamps, NOI, also in Packages 794, 817, 1424, 1467, 2204 or 5F;
Lighting Fixtures, NOI;
[Other Articles Listed—No Change.]
In boxes or crates, subject to Items 170 and 171 and having a density
in pounds per cubic foot of, see Note, item 109706:
Subs 1-11
No Change.
109701
NOTE—No Change.
109702
NOTE—No Change.
109703
NOTE—No Change.
109704
NOTE—No Change.
109705
NOTE—No Change.
109706
NOTE—No Change.
Analysis
This proposal originated from Research Project 1125, which was initiated in February,
2011 in response to an interpretive request from a member carrier on so-called brooder lamps.
The products were ultimately held to be classified under item 109460, naming artificial sunlight,
heat ray or therapeutic lamps, with an assigned class 125. Brooder lamps are a type of heat
source for newly incubated chicks or other animals. Information submitted by the carrier
indicated densities of 3.65 and 3.66 pcf, which is inconsistent with the currently assigned class.
CCSB guidelines for class 125 call for a minimum average density of 7 pcf.
Research Project 1125
During the course of Research Project 1125, questionnaires regarding the transportation
characteristics of artificial sunlight, heating or therapeutic lamps were sent to 20 associations
and 171 potential manufacturers or shippers in March and May of 2011. From these mailings,
only one shipper responded with usable information. There were no responses received from
the various associations. As a consequence, this analysis is based largely on data obtained
from the CCSB’s Density Study1 with the submitted shipper data and the aforementioned
carrier data included.
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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©2011 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2012-1
SECTION I
SUBJECT 14
History of Provisions
The provisions of item 109460 were adopted from the rails in 1936 and first appeared in
LTL-1, effective April 1, 1936, at a rating equivalent to the present class 125. The item has
remained substantially unchanged.
About Artificial Sunlight, Heating or Therapeutic Lamps
Research reveals that heat or artificial sunlight lamps have been around for some time.
In this regard, light or phototherapy, sunlight and brooder house lighting applications were
apparently very much in vogue back in the early 1900’s. In fact, sunlight lamps and other
comparable units were originally sold as medical devices designed for the treatment of skin
conditions, pain relief and therapeutic stress2. Some early depictions of irradiation lamps, heat
ray lamps and sunlamps are shown below.
Irradiation Lamp
Heat Ray Lamp
Sunlamp
There are many product styles and shapes today, including floor standing, desk
mounting, clamp type and others. Other applications for heat lamps or warmers include food
preparation areas of restaurants, reptile tanks and animal pens, to name a few3.
2 Contemporary
lamp units equipped with full-spectrum lights are now used to treat acne, sleep, bipolar
and seasonal affective disorders, among other conditions. Other model options include ultraviolet and
radiation lamps for tanning, and phototherapy lamps designed to treat the mood symptoms of
depression associated with pregnancy, attention deficit hyperactivity, bulimia and behavioral
disruptions.
3 In the broadest sense, ordinary household white incandescent bulbs can also be used as heat lamp
fittings; red and blue bulbs are sold for use in brood lamps and reptile lamps. The trend though is for a
gradual phase-out of the incandescent bulb as an electric light source. Fluorescent bulbs, compact
fluorescent bulbs, cold cathode fluorescent bulbs (CCFL), high intensity discharge (HID) bulbs, and lightemitting diodes (LEDs) constitute some of the newer technologies to improve the ratio of visible light to
heat generation. Some jurisdictions, such as the European Union, are in the process of phasing out the
use of incandescent lightbulbs in favor of more energy efficient lighting. In the United States, federal law
has scheduled the most common incandescent lightbulbs to be phased out by 2014. (http://
en.wikipedia.org. accessed June, 2011)
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As mentioned, brooder lamps are also a type of heat lamp and resemble other models
in size and function. They are used for livestock separation and hatching. The models below
show the crossover of units that are closely related in both the clinical and animal fields.
Brooding Lights
Sunlamps
Mineral /Therapeutic Lamps
In addition, there are lamps currently classified in item 109460 that closely resemble
lamps embraced under item 109700 but differ only in representation, usage and perhaps the
bulb used to equip the unit. Shown below are two types of floor standing lamps that are
almost indistinguishable; the lamp on the left is used as a heat source whereas the one on the
right is used as a light source.
Heat Lamp per item 109460
Reading Lamp per item 109700
Transportation Characteristics
Density—Based on the 692 density observations on the record, the density ranges from 1.04 to
34.68 pcf, with an average of 7.07 pcf. (The density study does not indicate the specific type
of lamps identified by use, i.e., artificial sunlight, heating, therapeutic, brooder, etc.)
Nonetheless, the density figures are, for the most part, spread throughout the range, as shown
in the frequency distribution on the next page.
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SUBJECT 14
Frequency Distribution
38%
% of Figures in Interval
40%
35%
30%
25%
25%
20%
14%
15%
9%
10%
5%
5%
0%
2%
4%
2%
1%
0%
0%
Density Intervals (pcf)
Handling—The involved lamps are tendered for shipment in fiberboard boxes that may or may
not be palletized for shipment. There is no indication of any unusual handling considerations.
Stowability—There is no indication of any unusual stowing considerations. However, given the
inherent fragile nature of lamps, care should be taken to avoid crushing by heavier freight with
which stowed.
Liability—There is no indication that the factors which comprise the liability transportation
characteristic present any unusual or significant considerations. There is no evidence of an
unusual claims problem nor has any current data been developed regarding value per
pound.
Relationship to CCSB Policies and Guidelines
CCSB updating policy calls for establishing or amending classification provisions for
commodities that are a source, or potential source, of interpretation disputes so as to
eliminate or avoid those disputes. As mentioned, there was some question as to the
applicable NMFC description for brooder lamps, i.e., artificial sunlight or heating lamps, per
item 109460, or more generally as lamps, NOI, per item 109700. It was the CCSB’s opinion that
item 109460 applies.
CCSB clarification, simplification and uniformity policy calls for combining descriptions
embracing related commodities. While item 109460 applies on artificial sunlight, heat ray or
therapeutic lamps, other comparable lamps are classed under the catch-all provisions of item
109700. At this point it should be mentioned that the present language of item 109460 is
inconsistent and redundant — utilizing the term ‘lamps’ to identify both the lighting/heating
device and the incandescent bulbs; also, the use of the modifier ‘electric’ twice as a
restrictive measure in this context is unnecessary and superfluous. At the same time the entry
©2011 National Motor Freight Traffic Association, Inc.
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SUBJECT 14
allows only for incandescent lightbulbs, while the evidence of record shows that other types of
lightbulbs are also being utilized, consistent with a general industry phase-out of incandescents
in all market segments. Canceling item 109460 with reference to the density-based provisions
of item 109700, and specifically listing artificial sunlight, heating and therapeutic lamps —
without restriction as to the type of bulb — as part of the ‘viz.’ listing, would be consistent with
CCSB policy and address the interpretation issue.
It is also CCSB policy that provisions reflect a commodity’s known transportation
characteristics. Information of record shows that artificial sunlight, heating or therapeutic
lamps have an overall average density of 7.07 pcf, with a range from 1.04 to 34.68 pcf, and no
unusual or significant handling, stowability or liability characteristics. The frequency distribution
shows that the majority of density figures of record are clustered around the average density
of 7.07 pcf. However, maintaining a separate description would not address the existing
interpretation problem. Moreover, the overall density range of 1.04 to 34.68 pcf is wide and
well within the range of densities considered in the establishment of item 109700 4.
For these reasons, this proposal is consistent with CCSB policy and precedent.
Docket 2004-3, Subject 10 (August, 2004) involved the cancelation of two separate groupings applying
on various lamps, lighting fixtures and parts thereof, and the consolidation into a single density-based
entry; the information of record indicated a range in density from 0.06 to 144.58 pcf, with an average
density of 7.16 pcf.
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©2011 National Motor Freight Traffic Association, Inc.