Manager, Mailing Standards

U.S. Postal Service

475 L’Enfant Plaza SW, 11th Floor N

Washington DC 20260-3436

Letter-Size Booklets and Folded Self-Mailers

MailingStandards@usps.gov

 

To Whom It May Concern:

In my first response I stated that the Postal Service had worked cooperatively with the mailing industry on slim jims (bound letter sized catalogues) greater than 1/8 inch thick, but that no conversation, investigation, or testing had been done in conjunction with folded self mailers (unbound letter sized mail pieces). Since there have been no discussions or testing that involved the industry, the Postal Service has not reached a consensus about the need to change: the current definition of self mailers and booklets, the current size requirements for the letter mail stream, tabbing requirements for thin booklets and self mailers, what ever changes you have in mind for cards, or any future changes planned for the envelope mail stream.

Therefore, the proposed rules in the Federal Register filing (12/29/08) should be withdrawn! 

Rules for thick (1/8 inch or greater) slim jims should be rewritten and republished as a “New” limited proposed rule with an adequate comment period. Because of your work with the industry on slim jims, there is a growing consensus that changes need to be made to this design when it is thicker than an 1/8 of an inch. The Postal Service, to its credit has provided design changes to adapt this difficult to process piece so it will run on the DBCS, but these proposed design changes (tab placement and size) are just one of many possible solutions to processing problems. Included in the “New” proposed slim jim rule should be a provision for the testing and approval of alternative designs.

How can the industry develop innovative concepts, designs, or materials if we are precluded by rigid rules from being able to test, prove, and use these innovations in the mail stream? Customers should be encouraged to test their concepts locally through their MDA’s with final testing and approval administered by the PCSC in New York. As new designs are tested and approved for the automated letter mail stream, they should be incorporated into the DMM or in a companion publication containing mail design best practices and approved alternatives to the DMM.

3.1 Basic Standards  In this section the last sentences says “Machinable and automation pieces must not be sealed with tabs on the bottom edge.” As explained by postal personnel during industry meetings, placement of tabs on the bottom of the mail pieces “are a disaster.” This change seems reasonable to me but I want to take this opportunity to point out why tabs on the bottom are such a disaster. The primary reason for this problem is the mailing industry’s inability to consistently place tabs flush to the mail piece. As a piece of mail travels the belt path on the DBCS, tabs hanging below the edge of the mail piece catch and snag on the equipment as they are being processed. The advantage of tabbing mail on the top edge is there is nothing for tabs that overhang the mail piece to snag during processing.

3.2 Paper  Again, finally an official chart comparing various paper weights. But the primary issue remains that there is no way for anyone other than the original printer to know if pieces are in compliance. The same issue arises with the term “high tear strength paper stock.” No one in the industry understands this term or can tell if the products they are producing meet the specification.

All specifications cited in the DMM must be verifiable by acceptance units. If acceptance units test for compliance with postal standards, the industry will comply with those standards. If acceptance units can not test mail piece parameters against DMM standards, then those in our industry that don’t know or don’t want to know the rules gain a financial advantage over those that adhere to the rules.

What drives the industry crazy is when we work hard to comply with the rules and then see improperly prepared mail pieces in the mail stream. Other than making someone at headquarters feel good, what value are rules that can not or are not  verified and therefore ignored by the industry?

3.3 Static and COF  Engineering terms, scientific papers, and theoretical testing procedures are a waste of ink on paper! Some in the industry recognize that slick pieces cause major problems for postal processing. Plastic and plastic coated mail pieces arrive in my mail box on a regular basis but these pieces are, in most cases, banned from the mailstream by the current DMM. Again, a plastic coated mail piece or mail pieces in plastic envelopes are pretty easy for acceptance units to identify and yet these products are currently being accepted at auto letter rates.

One plastic coated card, which is and has been slick from its introduction at a National Postal Forum, gained USPS approval after working with headquarters and the engineers at Merrifield. Sherry Freda was quoted in a January 31, 2005 article in Business Mailers Review “…the advantage of headquarters involvement is that the engineering division in Merrifield, Va., can test the sample product using all the equipment that mailing might encounter in the country, rather than the equipment that’s available in a local center. The approval took about eight weeks.” Apparently after extensive testing, the COF of this card was not an issue. If the slickness of this card is not an issue then neither is the slickness of other letter sized mail!

After my “First Response” to the proposed rules, I was contacted by a person that works in the development of inks and coatings used by the printing industry. He belongs to PIA (Printing Industries of America) and told me that in some segments of the packaging industry Coefficient of Friction of inks, coatings, and paper is a very important component in the printing and packaging process. He said that it is possible to develop a usable COF standard that could be verified with a fairly simple machine having an estimated cost of $3,000.  Apparently it would take a year or more for the USPS to work with the industry in developing reasonable standards. PIA has a group called GATF. My contact said that this is the group the Postal Service should contact to work on setting standards for COF.

The question for the USPS is whether it is worth it to the Postal Service to spend a couple years working with an industry group like GATF to test and develop relevant standards and then spend $3,000 per acceptance unit for the verification equipment to ensure the standards are met? Or is this an occasional problem, better handled in the plants rather than spending time and money to prevent the problem?

3.4 Dimensions  In the section on dimensions and shape, if you were to delete the words “except folded self-mailers and booklets…” and delete all of sub point “d. ”, this section would be OK. Another words, leave the existing dimensions alone. These are your standards which you established years ago. Your equipment has not changed but the industry has adapted its equipment to match the standards! There has to be a massively compelling reason to make changes! The Postal Service hasn’t stated any reason for making these dimensional changes let alone reach a consensus with the industry. Therefore, leave the standards as they are now.

Fundamentally I do not believe you, or for that matter many in the industry, understand how a minor change in mail piece size would severely impact our industry. From changing templates, guides and the redesign of equipment, to the reeducation of all graphic art designers, sales people, customers and postal employees, everything written, published or posted would have to change to reflect the new dimensions. And, an error in design or production of mail pieces would effectively double the postage cost of the mailing. It’s mail owners that will ultimately absorb all of these costs.

3.6 Weight  I personally would like to see a card that weighs 3.5 ounces and is still machinable. Maybe cards should be removed from this section.

3.12 Tabs, Tape, Glue  Why can I use a piece of tape that is ¼ inch wide on a mail piece but my tabs, made of the same or similar material, must be 1.5 inches wide?  You have achieved consensus within the mailing industry that some perfs don’t work. You have not proven that all perfs fail. In fact your own studies prove that some perfs are acceptable. See my first response for more details.

3.12 a. – b.  If there are going to be specifications for the construction of tabs, minimum paper weight or shear strength, set up a registry of approved tabs (similar to poly wrap) and the industry will purchase and use only those tabs. These proposed specifications can not be verified by the mailer or acceptance units and will be ignored.

3.12 c. – d.  By definition, on pieces requiring three tabs, this rule precludes the use of any tabbing material other than paper. On booklets, the bottom tab must be within ½ inch of the bottom of the mail piece. Tabs in the barcode clear zone (5/8 off the bottom) must be paper. Vinyl tabs and I assume plastic tabs (though not identified in “d”) along with cellophane tape are not allowed in the barcode clear zone therefore only paper tabs can be used.

3.12 f.  Two inch tabs are not readily available. Most of the existing tabbing equipment owned by the industry can not apply two inch tabs. In fact most table top tabbing equipment can not apply 1.5 inch tabs. It would show real insight and understanding of the industry you lead, if proposed rules reflected the capabilities of the equipment currently used by the industry. Expecting the entire industry to redesign, manufacture, buy, and implement new equipment to meet “incremental changes” in rules is either hubris or ignorance of the industry you serve! Certainly, this is a course of action only a governmental monopoly would attempt with such a cavalier attitude.

3.12 g.  It’s amazing that with COF, shear strength of paper and various other detailed specifications there aren’t any specifications for the glue used in lieu of tabs. I doubt that all glues are created equal and have no idea how the correct glue could be verified if it were used.

With changes that affect the entire mailing industry, the Postal Service must work with, educate, listen to and learn from its customers. Being a governmental monopoly does not remove the need to achieve consensus among stake holders. The problem with these proposed rules is that in your effort to reduce your costs you have cut the industry’s production speeds by more than half, increased equipment and real estate costs, and increased consumable costs.

The question postal management has never asked itself, while designing and implementing the most complex and expensive changes the industry has ever seen (from IMB to NCOA to these proposed rules) is: will the USPS be able to reduce postage costs enough to counter the massive increases in production costs mail owners will be forced to pay to stay in the mail stream?

Specifically for self mailers, are you going to cut your processing times in half, with a corresponding reduction in postage, to compensate for doubling the industry’s processing times? My guess is NO! These issues are why the industry consistently asks for consideration of the “lowest combined costs.” These proposed rules prove to the industry that the Postal Service is not listening. Increasing the cost of production without a corresponding decrease in postage drives mail owners’ total cost. Higher costs mean less mail and we both lose.

Gaining consensus for rule changes is easy to accomplish.  We live in the digital age.   Use some of that gee-whiz technology and show your customers the problems your machines are having. Show the industry how our pieces are running on your equipment. The engineers have a video of plastic cards being processed. In the video the cards flow out of the stacker like a waterfall, landing on the floor. This and other videos of problem pieces would quickly gain consensus on the most egregious problems you have.

If you would have shown the industry the DBCS machines shredding and tearing off covers of slim jims, many in the industry would have researched solutions to the problem. If light weight cards are a problem, bring those videos to the NPF and local PCC’s and most mailers will take corrective action. If our mail pieces are too tall, show video of them jamming the equipment. Mailers do not want their mail damaged and will willingly make changes if they are aware of the problems. Let your customers see the issues, and many of your problems will disappear without the need for new rules.

 

Sincerely,

Todd Butler

Butler Mailing Services, Inc.

513-870-5060