Revised Mailing Standards on Folded Self-Mailers and Unenveloped Mailpieces

The Postal Service will revise Mailing Standards of the United States Postal Service, Domestic Mail Manual (DMM[supreg]) 201.3.14, to provide new standards for folded self-mailers (FSM) and unenveloped mailpieces that are mailed at automation or machinable prices. To avoid confusion with revised standards for FSM mailpieces having loose enclosures, the Postal Service renames mailpieces that are designed to carry discs, and expands the standards that apply to tabs to include folded self-mailers.

Effective January 5, 2013.

FOR FURTHER INFORMATION CONTACT: Craig Vance (202) 268-7595 or Susan
Thomas (202) 268-8069.

On August 15, 2011, the Postal Service published a Federal Register proposed rule (76 FR 50438-50441) for changes to the design and construction of folded self-mailers and unenveloped mailpieces that are mailed at automation or machinable prices. The proposed standards were issued after two years of collaborative work with mailers to analyze and test a wide variety of folded self-mailer letter-size designs. In response to the proposed standards, the Postal Service received 51 comments. Many of those who commented provided input on more than one aspect of the proposal. Each comment was given consideration and modifications were made to the proposed standards when possible. This final rule will be adopted based on our proposed rule with only minor revisions. These standards do not apply to cards, envelopes, booklet style letters, or mailpieces designed to carry discs.

The final rule includes DMM recommendations for design elements and sealing methods for FSMs. To avoid confusion about the types of mailpieces included in this change, the Postal Service renames mailpieces that are designed to carry discs in 201.3.4. To simplify the requirements that apply to tabs that can be used to seal unenveloped letter-sized mailpieces, DMM 201.3.11 is modified to include folded self-mailers. The final rule also includes recommended revisions to the proposed requirements based on observations of a wide variety of FSMs tested over the past several years.

Although the effective date of these revisions is not until January 5, 2013, we encourage all customers who prepare FSMs mailed at automation or machinable prices to begin conversion to these design concepts as soon as possible.

A folded self-mailer is formed of panels that are created when one or more unbound sheets of paper are folded together and sealed to make a letter-size mailpiece. The number of sheets in the mailpiece and the number of the times the sheets are folded determine the number of panels. Sheets that are bound by one or more staples are not considered folded self-mailers even when all other preparation recommendations are met.

The maximum height for all automation and machinable FSMs is 6 inches and the maximum length is 101/2 inches, with a maximum thickness of 1/4 inch. The maximum weight of three ounces is applicable to all mailpieces prepared without envelopes.The paper basis weight for folded self-mailers is based on book-grade paper unless otherwise specified and varies depending on the total weight of the mailpiece and/or optional elements that are incorporated in the design. The final fold must be at the bottom for all designs except oblong style pieces. For oblong-style FSMs the final fold is on the leading edge. Tabs cannot be placed on the bottom open edge of an oblong-style FSM. A minimum of two tabs will be required to seal all FSMs when tabs are used as the sealing method. Tabs used as seals may not have perforations. Glue may be used as an alternate sealing method when applied according to the standards for FSMs.

After January 5, 2013, folded self-mailers that do not meet these requirements will be assessed postage as follows: First-Class
Mail[supreg] and Standard Mail[supreg] customers will pay nonmachinable prices; Periodicals mailers will pay nonbarcoded prices.

Overview of Comments

Eleven commenters
recommended that the proposed standards be abandoned and asked that no changes to the existing mailpiece format be made at this time. The commenters cited the economy and the lack of equipment capable of producing the types of designs expressed in the proposed standards. Commenters were also concerned about time and cost incurred for mailpieces that may already be designed and produced, but not mailed. Many new formats and sealing requirements not defined in current standards for FSM are added. To accommodate the mailing industry, the Postal Service will delay adoption of the new standards until January 5, 2013. This postponement will provide enough time for mailers to complete outstanding contracts for mailpieces that do not meet the new standards and will allow those pieces to be entered as automation compatible folded self-mailers prior to the effective date. Mailers entering FSMs before the effective date are encouraged to design and prepare their mailpieces using these standards. Four commenters expressed concern regarding the Postal Service’s proposal to require an additional tab on mailpieces weighing more than one ounce. As pieces get thicker and heavier it becomes more difficult
for those pieces to pass through processing equipment. The mailpieces do not retain their integrity and cause jams and damage to the mail and processing equipment. Heavier weight FSMs experience more stress on the leading edge, especially when it is not a folded edge. An additional tab placed on the lower leading edge improves efficient feed capability
and serves as added protection for the mailpiece during processing. The additional tab also maintains closure as pieces are handled and processed multiple times. Until January 5, 2013, three tabs are recommended to maintain sufficient sealing and to provide additional protection for heavier mailpieces and specific design formats.

Three commenters asked why it is necessary to limit the number of panels within an FSM. The number of panels affects the shape, thickness, and ability to create crisp folds required to maintain a streamlined shape. It also reduces the amount of stress placed on closures, and maintains the integrity of a mailpiece from acceptance to delivery. However, in order to provide increased options and ability to qualify for automation letter prices, the Postal Service will increase the allowed panel count to 12 for FSMs constructed of non-newsprint paper. Additionally, to accommodate the common practice of including half-pages in quarter-fold pieces made with newsprint paper, we increase the panel count for quarter-fold FSMs to a maximum of 24 panels.

Seven commenters expressed concern about the 101/2 inch-maximum length requirement. They expressed concern because smaller sizes will decrease the amount of space available to print advertising in a single mailpiece, and in some cases stock mailpieces will need to be redesigned to conform to the new size requirements. The FSM study revealed that, similar to booklets, mailpieces that exceeded 9 inches in length experienced a decline in machinability with significantly higher rates of damage and jams. The Postal Service maintains the proposed maximum length of 101/2 inches to balance the need for machinability with the customer’s need for the maximum amount of usable space.

Eight commenters questioned the thickness standards of .05 and .09 inches. USPS[supreg] revises the language to clarify that these thickness standards apply only to interior loose enclosures (single sheets that are not captured by the folds) and attachments. The standard for maximum thickness of a finished FSM letter is 1/4 inch, the same maximum thickness for all letter-size mail. Additionally, we allow the insertion of remittance envelopes, meeting all requirements for enclosed envelopes within automation letters, as enclosures when the envelopes are incorporated into the first (manufacturing) fold of the quarter-fold mailpiece format.

Two commenters asked that tabs made of material other than paper and tabs with perforations be used as seals for FSMs. To accommodate this request, the current standards that describe the types of materials used to manufacture tabs are expanded to permit their use for both booklets and FSMs. Tabs with perforations may not be used as a seals.

Nine commenters asked for clarification of tab placement and the number of tabs required. Section 201.3.14.4 is revised to clarify sealing mailpieces using tabs. Studies showed that sealing FSMs with one tab did not provide sufficient closure to withstand the rigors of automation processing for letter-size mail. The requirement to seal with a minimum of two tabs is retained.

Two commenters asked to use glue to seal the lead and trail edge instead of gluing along the top edge when the final fold is the bottom edge. We have revised and clarified the language to allow this as an additional sealing option.

One commenter suggested that the paper basis weight is unreasonably high. The basis weight of paper is one of the major factors that affect the machinability of a mailpiece. Pieces prepared with lower paper weight were unable to withstand the rigors of automation processing, resulting in higher rates of damage and jams and a diversion to more costly flat sorter and manual processing methods. We retain the paper basis weights as proposed.

One commenter asked about the perforation cut-tie ratio. The necessary cut to tie ratio is based on many correlative factors. A ratio that provides enough strength to prevent premature breaking of the perforation tie is needed. This need is balanced by the necessity of preparing a perforated line that can be opened by the recipient without causing unintended damage to the mailpiece. Due to the significant variation in cut-to-tie ratios of mailpieces currently in the mailstream, we modified the proposed standard and will allow a 1 to 1 cut-tie ratio for all perforated lines. The Postal Service will monitor the performance of mailpieces prepared with perforations and if the 1 to 1 ratio does not prove sufficient for machine processing, we will modify the standards to require a higher cut to tie ratio. Customers who have mailpieces that do not meet this reduced standard may ask that the FSMs be sent to the Pricing and Classification Service Center for review.

Three commenters asked for clarification regarding the need to print address information in a mid-to-left position. Section 201.3.14.10 is introduced as a recommendation for folded self-mailers produced on uncoated paper. Testing revealed higher rates of delamination and peel-back (cosmetic damage) to the lead edge of uncoated (raw) paper. This type of damage often exceeded 1/2 inch in length and impeded the ability of letter sorting machines to read address elements.

With this final rule, the Postal Service implements requirements and options that describe the construction of folded self-mailers and other unenveloped mailpieces. These standards allow significant design flexibility while maintaining mailpiece automation compatibility and address most current and proposed designs. Mailers designing and mailing FSMs before the effective date are encouraged to prepare mailpieces using these standards.

The Postal Service adopts the following changes to Mailing Standards of the United States Postal Service, Domestic Mail Manual (DMM), incorporated by reference in the Code of Federal Regulations.

State of the Postal Service Part 2

Continued from Part 1

As we continue to review our volume, revenue and financial projections for fiscal years 2012 through 2015, it has become apparent that our financial situation is becoming even more precarious. First-Class Mail volume is declining even more rapidly than we had previously predicted. Standard Mail volume is flat, and in any event cannot adequately compensate for the declines in the much more profitable First-Class Mail that we are experiencing. Therefore, it is clear that we must reduce costs at an accelerated pace.

Our most significant area of cost is in compensation and benefits, and one key driver of those costs is simply the sheer size of our workforce. Therefore, the Postal Service has to be able to reduce the size of our workforce if we are to have any hope of insuring that our costs are less than our revenue. Based on current revenue and cost trends, and assuming a move to 5-day delivery, the Postal Service can only afford a total workforce by 2015 of 425,000, which includes approximately 30% lower cost, more flexible, non- career employees.

Attrition and certain other measures will allow us to achieve a portion of the savings needed to match expenses with revenue by 2015. We estimate that attrition will only result in a staff reduction of approximately 100,000. However, in order for the Postal Service to reduce complement to meet projected volume degradation, we must eliminate roughly 220,000 career positions between now and 2015.

In order to eliminate the remaining 120,000 career positions by 2015, to restore the Postal Service to financial viability, it is imperative that we have the ability to reduce our workforce rapidly. Unfortunately, the collective bargaining agreements between the Postal Service and our unionized employees contain layoff restrictions that make it impossible to reduce the size of our workforce by the amount required by 2015. As explained below, it is not likely that the Postal Service will be able to eliminate these layoff protections through collective bargaining, given the nature of collective bargaining and interest arbitration. Therefore, a legislative change is needed to eliminate the layoff protections in our collective bargaining agreements.

As a Solution we recommend that reductions in bargaining unit postal employees should be governed by the RIF provisions applicable to federal competitive service employees. These provisions must supersede existing contract provisions and should not be subject to modification or supplementation through collective bargaining to avoid conflicts of law and to maintain necessary continuity among bargaining units.

Applying the federal statutory and regulatory competitive service process to the postal bargaining unit workforce could be done in a manner that would produce the following positive results:

The Postal Service could quickly reorganize and right size its bargaining unit workforce utilizing one set of established rules.
Postal bargaining unit employees would have the substantive and procedural protections provided by RIF rules, but collective bargaining agreements would be prohibited from having no lay-off clauses. Issues related to lay-off and reassignment to lower levels would be removed as subjects for collective bargaining.
Postal bargaining unit employees would challenge their lay-offs or involuntary reassignments to lower levels to the MSPB rather than through the grievance procedure.
Veterans’ preference is preserved.
The Postal Service would have a significant tool to return to financial solvency, thus protecting businesses and the majority of jobs for the hundreds of thousands of postal and other employees in the postal industry.

The recommended statutory change would be to modify Title 39, United States Code, to apply the RIF provisions of Title 5 and implementing regulations governing the competitive service to the Postal Service’s bargaining unit employees and to make clear that collective bargaining cannot modify or add to such rights, nor limit the rights of management that are part of the current federal competitive service RIF process.

In Conclusion We recognize that asking Congress to eliminate the layoff protections in our collective bargaining agreements is an extraordinary request by the Postal Service, and we do not make this request lightly. Indeed, the Postal Service generally believes that it and its unions should be free from Congressional mandates as to the provisions of its collective bargaining agreements and that the Postal Service is best served when the bargaining parties can resolve their differences through collective bargaining. However, exceptional circumstances require exceptional remedies.

The Postal Service is facing dire economic challenges that threaten its very existence and, therefore, threaten the livelihoods of our employees and the businesses and employees in the broader postal industry and overall economy, of which the Postal Service continues to play a large part. If the Postal Service was a private sector business, it would have filed for bankruptcy and utilized the reorganization process to restructure its labor agreements to reflect the new financial reality. Because this option is not available to the Postal Service, we believe that this extraordinary request is a key to securing our future and our continuing ability to provide universal service to our nation.

We are urgently engaged with Congress and the Administration to achieve a legislative resolution that will allow us to best serve our customers. Whatever the outcome, not only will it affect the Postal Service – it will shape the future of the entire mailing industry. Meanwhile, our commitment to providing excellent delivery service and connecting senders and receivers across the nation remains unchanged. We will continue to focus on our customers, and to partner with the mailing industry to ensure that together we are positioned to fulfill the changing needs of American customers.

State of the Postal Service Part 1

Information provided by the US Postal Service:

This recession has been particularly cruel to the postal service, already battered by the popularity of e-mail. Total mail volume is declining and just Last year we saw the biggest decline in mail since the Depression: volume fell by 4.5%, or about 9 billion pieces.

The postal service continues to loose volume in it’s largest, most profitable segment: First class mail. The postal service ended the 2008 fiscal year with a $2.8 billion loss, and the next two years may well be worse.

In response to the continuing decline in mail volume and revenue, the Postal Service has taken unprecedented steps over the past decade to reduce cost in areas within its control, including cost reductions totaling $12 billion in the past four fiscal years. The Postal Service has already identified and is pursuing a number of needed legislative changes that would help to return it to solvency.

Actions have been taken across the board to address the financial situation including: Work hour reductions, distribution compression, national distribution center realignment, facility optimization, equipment optimization and restructuring efforts.

The Postal Service is also undertaking, or has proposed, a number of additional steps to help it achieve the cost savings necessary to restore financial solvency. With respect to its delivery network, the Postal Service has and continues to aggressively pursue an optimization initiative that has led to fewer delivery routes, despite the growth in delivery points, along with more efficient usage of vehicles and fuel. In addition, the Postal service has urged Congress to allow 5-day delivery, an essential step in right-sizing the delivery network to reflect the fact that the Postal Service is now delivering a decreasing amount of mail to an ever-expanding number of delivery points.

The Postal Service is also closely examining its retail network, to identify opportunities where postal-operated facilities can be consolidated or replaced with alternate access channels that are both more cost-effective and provide greater access and more convenience for customers. The first step in this process was recently taken by the identification of approximately 3,700 retail facilities that will be studied for possible closure or conversion to contract postal services.
The Postal Service is also moving forward with efforts to streamline its mail processing network.

Currently, the Postal Service has over 500 facilities where mail is processed. Because of the decline in mail volume, referenced above, and the change in mail mix that has led to fewer pieces of mail requiring end-to-end processing, efforts are underway to continue to optimize this network using Area Mail Processing studies and other consolidation initiatives. We anticipate reducing transportation miles and costs and reducing the number of processing facilities to below 200.

Continue to State of the Postal Service Part 2