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New Standards for Letter-Size Booklets and Folded Self-Mailers (proposed 12/29/08)

January 3, 2009

Todd Butler, President Butler Mailing Services, Inc.

The Postal Service has published a proposed rule for letter sized booklets and self mailers.  They are now asking for the mailing community to respond to the proposed rules, after which the USPS will write and publish a final rule that will govern non-enveloped letter sized mail.  The USPS has stated that revised standards governing postcards and letter-sized cards will be issued soon in a separate Federal Register notice.  Here is a link to the current proposed rule: Federal Register .

This white paper is designed to provide information on the proposed rule changes, raise questions about specific rules, question implementation/administration of those rules, and challenge some of the assumptions made by the USPS in developing these proposals.  I hope to fill in some background information on the process used by the Postal Service to establish these new standards and go into detail about appropriate sections.

This is from one customer’s perspective.  I have been the president of Butler Mailing Services for over 25 years.  Butler Mail is a small letter shop that since 2000 has worked extensively on developing letter sized mail pieces containing CDs and DVDs.  Our recently formed eKEY® Technologies group has over 40 different mail piece designs tested by postal engineers and approved by the PCSC to carry optical discs at automated letter rates.  The development of mail pieces containing CDs has involved extensive testing of design concepts on the machines used by the Postal Service to process letter mail.  Butler Mail’s work over the last eight years on difficult to process mail pieces provides a unique perspective of letter processing equipment, mail piece design, and the proposed rules.

Background information:

The primary work horse for processing letter sized mail is the DBCS machine.  It is a phenomenal piece of equipment that processes mail efficiently at high speeds.  With little human intervention, it is able to sort our mail down to the carrier level and put it into walk sequence for postal delivery.  Each piece of letter mail can be processed four to five times on this machine in preparation for delivery.

Depending on mail piece design, the DBCS can handle a wide variety of products.  It’s also a little temperamental.  We have found, in working with optical discs, that minor changes in design can have a tremendous affect on the machinability of the mail piece.  It’s not possible to make broad assumptions about what will or will not work on these machines, unless each design variant is systematically tested for compatibility.

I strongly believe that mail, as presented by the industry, must be compatible with the DBCS!

I also believe that before the USPS initiates any major changes in the DMM rules governing mail piece design, it must prove to the industry that the changes are absolutely necessary and in our mutual interests.  In March of 2008, the Postal Service met with an industry group to discuss problems the USPS was having with slim jims.  Slim jims are letter sized bound catalogues (no folds) with the spine beneath or to the right of the address.

During the meeting the industry group was informed that the DMM rules, which we have been following since 1996 for generating automation compatible mail, were not written for the machines that have been processing that mail since 1996.  The postal staff also went into issues the USPS has processing letter sized catalogues, presented the results of USPS testing of these catalogues, and outlined plans for future testing.  To the surprise of the group the future testing not only involved slim jims but also included folded self mailers and cards.

The biggest problem, according to the Postal Service, was with slim jims.  Covers were being torn off, pieces jammed at excessively high rates, perforated tabs opened up, or non perforated plastic tabs released on one side and stuck up during processing.  The group was informed that the USPS has been pulling letter sized catalogues from the letter mail stream and processing them on the flat sorters for many years, but with PAEA this cross subsidization between letters and the flat mail stream was no longer possible.  The group was also told that slim jims had to be compatible with the letter sorters or pay flat rate postage.

The question remains: why has the Postal Service waited twelve years to bring the mailing industry into the loop, finally letting us know that some of the products we produce are not compatible with automated letter processing?

Cooperation between the USPS and the industry:

At the March 2008 meeting, the Postal Service agreed to not only test samples produced for their own study but would also test samples from the industry.  The USPS also agreed to allow industry people to observe the slim jims testing.

Reports from the industry observers were devastating.  Most letter sized catalogues did not run on the DBCS machines.  Obviously, changes had to be made to the construction and tabbing of slim jims.

There was supposed to be a meeting between the industry group and the Postal Service in September for reviewing the findings of all of the tests and discussing possible rule changes.  Well, the Postal Service wasn’t done with the testing of their scientifically significant samples in September or October.  The joint industry/postal group finally got together the end of November via a webinar/teleconference.

A short slide presentation (35 slides) covered slim jims and the proposed new rules during the meeting.  Only one slide (#23) dealt with letter mail other than slim jims.  It told us that two and three one inch tabs on self mailers with heavy paper (70# and 100#) worked the best.  No other information on the testing of self mailers or cards was provided!

Disagreements with the USPS:

There were disagreements over the design of pieces to be tested between the industry and the USPS at the March meeting.  The USPS staff decided to allow separate testing by the industry to relieve the impasse.  The industry wanted to systematically test designs commonly found in the mail stream, with the goal of making these pieces more compatible.  The USPS wanted to test a broader range of samples, but many of the USPS designs were unfamiliar to industry participants.  Though most of the industry people present produced slim jims, there was a concern that slim jim testing had intentionally morphed into a revamp of all non-enveloped mail.

Repeatedly the industry warned postal management that a major revamp of DMM rules could have a very negative impact on industry costs and mail volumes.  It was strongly recommend by the industry to take a minimalists approach to changes.  It was strongly suggested that the Postal Service identify and change only the rules necessary to eliminate the worst processing problems now, giving the industry time to work with the Postal Service in adjusting other products to be more compatible. This same theme was repeated during the November webinar, obviously to no avail.  Even though the USPS invited the industry to participate in some of the testing, the current postal attitude remains my way or the highway.

Preliminary conclusions:

The postal service has issued the rule changes they wanted.  The engineers have wanted to shift tab placement to the lead and trail edges for many many years.  Regards for the current economic climate, industry concerns, and industry warnings have all been ignored!

It is apparent to me that testing was done to justify decisions already made prior to the March 2008 meeting.  The industry inclusion in the slim jim testing proved (to the industry) the need for changes in this product.  USPS disregard and lack of inclusion (in the rules) of industry designs proven compatible with the DBCS machines during the industry phase of the testing, is arrogant and monopolistic not collaborative.

As for the testing of self mailers, if there was testing done the industry didn’t take part.  We sent in design recommendations for the USPS to test but have never seen any results of the testing.  As far as I know, no industry representatives were present for any of the proposed testing of self mailers, if indeed the testing was completed.  I suppose we should trust them, but then I’m a cynic.

The need for massive changes to our industry must be proven without a doubt, not based on an agenda seeking nirvana in the processing of mail.  For those involved in the slim jim testing there is no doubt that changes need to be made to the design and manufacturing of slim jims.  There is also no doubt that there are methods, other than the USPS proposed changes, that will make slim jims compatible with letter processing equipment. 

To retain the marketing viability of the letter mail stream, the industry has to have the option of developing new designs or the addition of new features to old designs without the constraints of a rigid set of rules, designed by the USPS to generate a homogeneous mail stream.  We must be able to test designs locally for compatibility with processing equipment.  Final testing and approval should be coordinated by the PCSC in New York.  If customers can prove that a design is compatible with processing equipment, that mail should be accepted at automated letter rates.  And with “the current economic climate”, shouldn’t that be the goal of the United States Postal Service?

The proposed rules (You may want a copy of the proposed rules to follow this commentary)

201.3.1  Basic Standards

The USPS has closed a loophole in automation compatible letters.  In the past you didn’t need to tab pieces to claim non-automation (machinable) rates.  With the new rules all of these pieces must be tabbed, with the only difference between automated rates and non automated rates determined by whether the piece carries a barcode.

The second change in this section is that self mailers can not have tabs on the bottom of the piece any more.  When the proposed automation rules were released in 1996, this was the rule.  The final rule was changed do to industry pressure.  

Problems arise in processing when the industry doesn’t place tabs tight to the bottom of the mail piece.  This is not a problem when tabs are on the top of the mail piece.  Non perforated plastic tabs cause the most problems, as they do not stay formed around the mail piece and stick up or hang down depending on the mail piece orientation.  Mail pieces with tabs hanging off the bottom snag as the piece is processed causing jams.

201.3.2  Paper

Finally, the USPS has provided a cross reference on paper weights.  But as a letter shop I have no idea what the basis weight of the paper my customers are using.  Not only am I not in the loop during the design phase of projects, many times I don’t know a job is coming until it hits my dock!

Printers using lighter weight paper than required by the DMM are able to achieve a competitive advantage over printers that follow the rules.  For a letter shop its life or death.  Either we process and enter the mail as presented to us or our competition will, regardless whether the piece meets the minimum standards or not!

And yet paper weight is absolutely critical to the machinability of the mail piece.  This proposed rule unnecessarily complicates compliance buy adding more variations.  If the Postal Service wants the industry to take this rule seriously, they must have the tools and processes in acceptance units to accurately measure the paper weight of mail pieces.  If there is no measurement system at all acceptance units, this rule will continue to be ignored!

What is "high tear strength paper stock"?  Is it a special grade?  How do I measure for this standard to ensure my customers mail pieces are in compliance?

201.3.3  Static and Coefficient of Friction

The problem the Postal Service has with static cling is that pieces stick together and are difficult to singulate so that the machines process one piece at a time.  Coefficient of friction is a measurement of how slick a piece is.  The engineers have video of slick cards that are uncontrollable by the DBCS and stream out of the machine like confetti during processing.  Static cling and slick pieces are causing problems for the Postal Service and need to be addressed.

But this rule does nothing to alleviate these problems!

The test methods listed under 201.3.3 are engineering specifications.  If you want to review these specifications you must BUY them form IHS Engineering.  ASTM D4470 costs $40 in hard copy.  ASTM D4917 costs $35.  If you purchase these papers you only receive the specifications for how to conduct the tests, not the equipment (or education) necessary to do the actual testing.

I haven’t bought these reports but the description for ASTM D4470 says “The values stated in SI units are to be regarded as the standard.”  I don’t know what SI units are but they don’t appear to be the same as “KV” units used in the USPS proposed rule for static cling.  Is there a conversion table or has the USPS required a non-standard unit of measurement?

The use of ASTM D4917 as the standard for maximum slickness is very confusing.  The full name of this engineering specification is “Standard Test Method for Coefficient of Static and Kinetic Friction of Uncoated Writing and Printing Paper by Use of the Horizontal Plane Method.”  The description states “While the use of this test method is recommended for those grades only, it may be used with other types of papers giving specific attention to special paper characteristics and with the understanding that the precision and bias may not be the same.”  The description goes on to say that the test for fiberboard is different and covered under test methods D 4521 and D 3247.

Obviously this test method was not designed for coated paper or fiberboard.

So, the Postal Service has proposed a rule based on a scientific, engineering document that wasn’t intended for coated papers or fiberboard mailers.  MSPs (mail service providers) have to buy this document so we can establish the appropriate testing procedures, purchase the necessary equipment, and conduct the required tests, on mail pieces designed, purchased and printed by the mail owner that just wants his marketing pieces entered into the mail stream as quickly as possible!  Oh… and there is no way in hell acceptance units are ever going to be able to verify whether mail pieces are in compliance or not!

What acceptance units will do is a touchy feely kind of investigation, hold the mail for further testing and send samples off to the engineer that came up with this redicules unmanageable specification.  He in turn will test the piece and in 6 to 8 weeks (maybe) return the results, releasing the mail for delivery or collecting the appropriate non machinable revenue.

Common sense says that if the acceptance units can not verify compliance with proposed rules, then they shouldn’t be rules.

 201.3.4  Dimensions and Shape

This is where the USPS starts to change the rules in a significant way.  This section essentially establishes a size differential within letter sized mail depending on its design.  The traditional 6⅛ x 11½ dimension would only be available for enveloped mail (or mail sealed along all four sides).  Remember that the Postal Service plans to file soon, a set of proposed rules governing cards.  From comments made at the meeting in November by the USPS, it is safe to assume that cards will also be restricted to the dimensions in 201.3.15.3.

The reason for the dimensional changes in the proposed rules is not based on problems processing pieces that meet current standards.  After extensive testing, engineers have decided that when they receive mail sized for an EMM tray, process it on a DBCS, then place that mail into the smaller MM trays without sleeves, and stack other trays of mail on top of them, the mail on the bottom of the stack gets bent and warped so that it can’t be reprocessed on a DBCS after being shipped to another facility.

This apparently is a huge problem for the Postal Service and the only solution is to reduce the size of our marketing pieces, not switch to using EMM trays, with sleeves, to transport the mail between plants.  A secondary goal of the Postal Service may be to have just one tray size to manufacture and inventory.

Postal managements’ ultimate goal is to gradually draw down the height on all letter sized mail to 5.5 inches as evidenced in a pre-release version of the proposed rules and the webinar slide presentation given to the industry (November 2008).  The 5.5 max height in the slides was explained away by the postal presenter as a typo, stating that it should have been a max height of 6 inches.  During the meeting when asked why the ⅛ inch reduction in height, the postal response was that “this is an indication of the direction we are going”.  No other explanation or further discussion.  They made no claims about their testing, increased machinability, or processing speeds.

To be clear, mail pieces that are 6⅛ are not causing jams because they are an ⅛ of an inch too tall for the machines to handle!  Reducing the height by an ⅛ of an inch will not reduce or prevent USPS caused damage when transporting mail.  Therefore this size reduction is just one step to reducing letters to a much smaller dimension. 

The goal of moving to a 5.5 inch max height is dictated by the desire to transport all letter sized mail in the smaller MM trays, period!  The apparent game plan is to reduce dimensions of Booklets and Self Mailers with this proposed rule, cards will shrink in the next Federal Register filing, and (I have been told) the dimensions of envelope mail could be reduced as soon as next year.

201.3.6  Maximum Weight…

Not much change here, but I would like to see a card that is letter sized, weighs 3.5 ounces, and can be processed on a DBCS.

201.3.7  Heavy Letter Mail (over 3 ounces)

No changes here either.

201.3.12  Tabs, Tape, and Glue

The Postal Service is increasing the minimum tab size to 1 inch for self mailers, which are proposed to be a single sheet of paper (see 201.3.15.1 below), and 1½ inch tabs for booklets, which would include unbound multi sheet mailers (see 201.3.16.1 below).  Comments from postal employees have indicated that 2 inch tabs are the preferred tab size for all products! See 201.3.12f below for what the proposed rules “strongly recommend.”

In the slim jim tests observed by the industry, the USPS proved to the observers that there was a significant difference in cling strength between 1¼ and 1½ inch tabs.  So maybe 1½ inch tabs are necessary for slim jims tabbed according to the USPS’s proposed rule.  The Postal Service has not proven the need for the three tab placement or tab size proposed for unbound multi sheet self mailers!

A major complaint from the Postal Service about processing problems has been with plastic tabs, both perforated and non-perforated.  Many perforated plastic tabs open up during handling and processing and therefore are useless.  The USPS eliminated all perforated tabs in the proposed rules, making the assumption that no one will use a plastic non-perforated tab.  If people continue to use plastic tabs, and they will, the Postal Service will perpetuate some of their existing problems.  Plastic tabs have memory and do not stay formed to the mail piece.  The older the stock the more likely plastic tabs will stick up, causing handling and processing issues.

The engineers also tested an experimental perforated vinyl tab on booklets.  Two of these tabs were placed on the top of two different sized booklets constructed of 70# and 80# text grade paper.  The tested tabs were 1 inch and 1½ inch in size. The manufacturer of this product was told by the engineers that the perforated vinyl tab performed as well if not better than paper tabs.  Unfortunately the manufacturer was never issued a promised letter authorizing the use of this product.  Clear vinyl tabs do not have memory like plastic tabs and will not release, sticking up or down, depending on mail piece orientation.

What I don’t understand in the proposed rule is the ability of mailers to use cellophane tape.  Cellophane tape can range in width from a ¼ of an inch to three inches.  Tabs are required to be circular, tape is not.  I could use, according to this rule, a piece of tape that is ¼ x 1½ inches on slim jims and conform to the proposed rule.  If I can use a piece of tape of this dimension why can’t I use a “tab” having the same dimensions?

3.12a/b  For translucent and opaque tabs the USPS has again provided standards that are not measurable by acceptance units and are not published by manufacturers.  If grams of force are important, why not provide a certification for manufacturers of tabs as the USPS did with poly manufacturers?  Then everyone could be assured that we are buying approved products.

3.12c/d  Note that tabs in the barcode free zone are required to have a paper face which eliminates the use of all tabs on multi sheet mailers (booklets), that are not made of paper.  See the section 3.16.4 below for more information.

3.12e  The requirement that tabs must be tight to the mail piece with a maximum overhang of 1/32 of an inch is not possible with existing in line tabbing equipment.  The Postal Service’s ability to measure the absurd is far greater than our equipments’ ability to accurately and consistently apply tabs on a piece of mail.   Therefore this rule is designed as a revenue generator; as the industry will be forced to pay nearly double the postage costs on mail pieces because our equipment or operators fail to meet the standard.

And when it comes to enforcement, many acceptance units are unable to count to two, ensuring current tabbing requirements are met, how are they going to accurately apply a technical measurement like 1/32 of an inch?

3.12f  This section strongly recommends that the industry use 2 inch tabs on their pieces.  Of course 2 inch tabs are not readily available, can’t be applied by legacy tabbers, will be very expensive, and won’t fit on many mail pieces.  How do you tab a 3½ x 5 booklet (unbound multi sheet mail piece) with 3 two inch tabs and not have tabs hanging more than 1/32 of an inch off the top edge of the mail piece?

Absurd?  No more than most of these proposed rules!

3.12g  Glue spots and glue lines are allowed to be used.  But with all the variations in glue formulations and all the specificity for tab strengths and adhesion, it should be noted that there aren’t any requirements for glue.  And of course, if there are requirements the industry should expect acceptance units to be able to measure for this standard also.  Minimum standards for glue must be established as many printers are talking about buying glue application units instead of using tabs under these proposed rules.

201.3.15  Folded Self Mailers

3.15.1  Definition

This proposed rule completely redefines the definition of booklets and self mailers as currently described in the DMM.  Currently Folded Self Mailers (201.3.14.1) are either a single sheet or multiple sheets folded to letter size.  Booklets (201.3.14.2) are described as having front and back covers with a bound edge.

The proposed rules define a Folded Self Mailer as a single, continuous sheet of paper with no binding, folded to letter size.  It then redefines the dimensions of what is letter sized (201.3.15.3).  This means that there can not be any attachments to the single sheet of paper.  If a sticker or foil embossed image is attached to the piece it is no longer a single continuous sheet of paper.

Customers could no longer attach an additional panel through the use of glue or put anything in a pocket formed by folding and gluing the single sheet of paper.  Cards made of paper or plastic can not be attached nor can scratch offs, post-it notes (placed on the inside of the mailer), and a whole host of other creative marketing ideas be utilized as part of a self mailer.  Mail pieces using pull tabs exposing a prize would also not be considered a self mailer.

What’s not clear is if all the creative ideas our industry has developed over the last 20 years would still qualify under the new booklet definition (210.3.16.1) or would they be banned from the letter mail stream.  Booklets after all, are defined as being made of paper in the proposed rules (201.3.16.1).

What is crystal clear is that any marketing pieces allowed to be mailed as booklets would have to meet the booklet tabbing rules, three 1½ inch tabs!

3.15.2  Paper Weight

Obviously the Postal Service didn’t test various paper weight possibilities or they would have eliminated a tri-fold self mailer constructed of 20# bond (50# Book Paper).  Anyone that has received one of these pieces in the mail knows that they do not stand up to the rigors of processing.

The heavier the paper used in the construction of mail pieces, the easier it is for the DBCS machines to process.  Testing we have done, shows that changing paper weights has a profound affect on the machinability of letter sized mail.  Heavier paper stands up to processing better with less damage to the mail piece.  Some participants found during the industry portion of the USPS mail piece testing that by using heavier paper for the covers of their slim jims, their catalogues could be processed successfully with two tabs positioned on the top of the mail piece.

The primary problem with using paper weights in DMM rules is that acceptance units can not verify the weight of the paper used.  We have paper weight requirements now that are not enforced, giving a monetary advantage to those that ignore the rules!  If there are going to be minimum paper weight requirements, acceptance units have to be able to verify compliance!

3.15.3  Physical Standards…

This proposed rule reduces the max height of a self mailer from 6⅛ to 6 inches.  As I stated earlier this decrease in size is not to accommodate the equipment.  It is an overall plan by the USPS to decrease the size of all letter sized mail pieces, including envelopes!

The Postal Service’s ability to measure the physical characteristics of a mail piece is far greater than the industries ability to consistently produce a specific size.  As an example, envelope manufacturing equipment has a tolerance (variation) of 1/16 of an inch.  The USPS ability to measure the size of a mail piece, through the use of Merlin, is 1/32 of an inch.  It’s obvious that folding equipment, trimming equipment and human operators can not set up and consistently run product to within 1/32 of an inch.

Currently the industry produces mail piece that are 6 inches tall or less.  This gives us an ⅛ of an inch cushion, incase folding and trimming equipment are off a little.  If they are off less than ⅛, the mail piece can still be mailed as a letter.  By reducing the max size, the USPS will force the entire industry to spec printing and folding to a max size of 5⅞ inches to allow for variations during the production of mail.  Think of the complexities and risk this adds to the industry from design, through acceptance.

The primary affect on the industry is that mail owners will continue to spec pieces at 6 inches or sales departments will miss quote the size of mail pieces to be 6 inches.  When the piece is more than 1/32 larger than 6 inches, the printer or MSP (mail service provider) will incur the additional costs of mailing the piece at flat rates.

The secondary affect on the industry is that the proposed changes in dimensions will require the redesign and printing of any catalogues or other collateral material that list mail piece sizes. Web pages, sales presentations and associated digital material will have to be updated along with the re-education of the entire direct mail industry.  Failure to re-educate and adjust internal systems and procedures in printing plants will have major monetary consequences as mail pieces that are 6 1/32 will no longer qualify as letters.

The Postal Service is also reducing the length of letter sized mail with the same issues.  Though 11½ inches (the current max) isn’t used much, and therefore not causing problems, 10½ is a very popular size that would have to be redesigned down to 10⅜.  The cost of down sizing standard templated pieces could be substantial for many in the mailing community as outlined above.  The penalty for accidentally producing longer pieces would nearly double postage costs!

The cost and disruption these changes will cause the mailing community is totally unnecessary considering that neither the processing equipment nor postal delivery personnel are affected by these dimensional changes! Our industry can not and should not absorb these costs for changes that deliver little or no benefit to the USPS!

A policy of incrementally reducing the size of letter mail over several years is absurd.  If the Postal Service wants to go to 5.5 inches as the max height, do it now!  Let’s resolve this issue once and for all.

3.15.4  Folded Self Mailer Design and Sealing

This proposed rule is unclear as to what it is trying to do.  First you can add additional tabs or seals? OK, I’m glad I have postal permission to make it as difficult as possible for consumers to open my mail pieces by adding additional closures.

Second, the industry is no longer able to design mail pieces with the open edges on the bottom (except certain styled booklets).  In the first proposed rules for automated letter mail in 1996, the final fold had to be on the bottom of the mail piece.  This rule revisits that design configuration.

Since non-perforated plastic tabs do not stay formed, thereby standing up or down (depending on mail piece orientation) and since the mailing industry is incapable of consistently placing tabs tight to the mail piece, these downward facing protrusions catch, snag and jam the equipment.  This part of the rule makes sense.

What the rule (I believe) also intends to do but doesn’t say it, is require tabbing and paper weight restrictions that can be found in “exhibit 3.15.4.”  My objections to this exhibit are with paper weight requirements that will not be verified during acceptance and tab placement being moved from the top of our traditional folded self mailers to the sides (lead/trail edges).

Tabs became a requirement in 1996.  Since then all tabbing manufacturers and customers have conformed to tab placement locations dictated by the USPS.  Now, in a matter of months, the Postal Service wants the industry to completely redesign, re-engineer and replace all of our tabbing equipment, associated processes, and in many cases the layout of our plants.

Some binderies have the ability to place tabs on the lead and trail edges.  But no existing in-line or table top pieces of equipment can place tabs on the lead and trail edges.  Operators of in line systems need to add bump turns, additional tabbing heads and more floor space.  Users of table top equipment will need to run their piece multiple times.  Many operations unable to afford new equipment will have to process mail pieces as many as three times to conform to these new rules.  All of these options will add major costs to producing letter sized mail.

And it’s all unnecessary!  Test results published by the Postal Service have proven that tab placement made no difference in overall processing or jam rates!

In phase one testing the Postal Service tested “Thin Booklets with Good Tabs” and provided the results at the March 2008 joint meting.  Slide 4 from the power point presentation shows the results of this testing.  Under lines L1 and L2 on that slide, the numbers show that two tabs on top of the mail piece performed slightly better than tabs on the left and right (lead/trail edge).

Two tabs on top had a lower transport and stacker jam rate.  The total jam rate for top and side tab placements were identical but it took less time to clear the machines after jams with tabs on top.  What was not tested was what happens if tabs are not tight to the mail piece.  If tabs were to stick up more than a 1/32 of an inch, I believe it’s pretty obvious that top mounted tabs will perform much better than tabs on the sides.

As mail is moved into the feeder section, passed through numerous gates, and deposited in the stacker section of the DBCS, tabs protruding on the lead/trail edges will significantly interfere with processing by snagging on the equipment and other mail.  With no height restrictions in the DBCS, protruding top tabs have nothing to snag on and will not come into contact with other mail during processing.  The simple fact is that protruding tabs on the lead edge will cause major feeding problems with processing equipment as the lead edge must be rectangular and straight to enter the feeder correctly.

The only category where two top tabs performed less well was a slight increase in the amount of damage incurred by the mail piece.  The reality is that damage is in the eye of the beholder.  If you want to reduce damage (undefined on this slide) and increase machinability, use a coated stock and increase the basis weight of the paper.  These two options were never tested by the USPS.

201.3.16  Booklets

3.16.1  Definition

The current definition of Booklets (201.3.14.2) is that they have a front and back cover with a bound edge.  The proposed definition (201.3.16.1) is that Booklets are multiple sheets of PAPER!  Booklets may be bound or unbound.

Unbounded multiple sheets of paper, folded to letter size, should not be reclassified as a booklet.  These thin self mailers perform differently in the machines than heavy, thick bound pieces and should not be classified as booklets with the same requirements.  They are currently self mailers and should remain folded self mailers.

Nowhere in the new definitions of self mailers and booklets is there a place for attached gift cards or any thing else made of non-paper products.  Therefore anything made from plastic will have to be inserted into an envelope, unless those rules are also going to change.  Booklets or self mailers presented to acceptance units containing anything that is not paper will have to be mailed at flat rates.

3.16.2  Paper

Various paper weight requirements are useless unless they can be verified during acceptance.

3.16.3  Physical Standards for Booklets

Are the same as for Folded Self Mailers, representing the downsizing of the mail stream.  Again, neither the equipment nor postal delivery employees are affected by the dimensions currently permitted and used by the industry.  See 3.15.3 above for more information.

3.16.4  Booklet Design and Sealing

Again the parameters are laid out in an exhibit (exhibit 3.16.4).

Be aware that non-paper tabs are not allowed in the barcode clear zone, which is ⅝ of an inch from the bottom of the mail piece.  Tabs on booklets are required to be ½ inch from the bottom.  Since the tabbing requirement places the edge of the lower tab into the barcode clear zone, this tab must be made of paper per proposed rule 201.3.12c.  Since it is not possible to apply some paper and some plastic (or vinyl) tabs, tabs on booklets will have to be paper.

One booklet configuration in the exhibit shows that two 1 inch glue spots within ¾ of an inch of the top and side edges of the mail piece are allowed.  If glue spots are allowed in this configuration then why can’t we use top mounted tabs instead?  Two tabs in this configuration on this design were not tested.

Summary Comments:

·         The Postal Service has not proven their need to revamp mail piece designs not described as slim jims.

·         Slim jims have been tested and proven to need changes to be processed as letters.

·         The industry should be able to explore and prove the effectiveness of other slim jim solutions.

·         Edge tabbing (lead/trail edge) on self mailers has been proven by USPS testing as unnecessary.

·         The paper weight of mail pieces are a critical factor for efficient processing, as such if paper weight is used in the rules this specification needs to be verified during acceptance.

·         The standards for static cling and coefficient of friction are a joke.

·         The Postal Service did extensive testing on slim jims with industry involvement.

·         Any testing done on the rest of the letter mailstream was done without industry involvement, and it shows!

In Conclusion:

USPS testing proved to industry observers that slim jims are a major problem for the Postal Service when they are processed as letters and that something needs to be done about this mail piece in respect to design and manufacturing.  The Postal Service tested and proved that the three tab configuration they promoted prior to testing, indeed works.  The Postal Service did not prove that their solution to the problem is the only solution that will make slim jims automation compatible.  Nor do the proposed rules allow any possibility for the industry to find, test or use a more consumer friendly solution.

The Postal Service must keep the industry informed (who knew they were having problems with letter sized mail) and find solutions that not only work for the USPS but solutions that will work for the industry.  In designing these proposed rules, concerns from the industry were not taken into account, alternatives were not investigated, and mutually beneficial solutions have not been found.

It never ceases to amaze the mailing community how little the Postal Service knows about its customers or the industry it serves!

Simple solutions to major problems:

·         Do not redefine letter size mail

·         Leave dimensions of letter sized mail at the current standards.

·         Adjust tabbing rules as proposed for slim jims

·         Allow the industry to test and gain approval for alternatives to the proposed slim jim tabbing requirements.

·         Update the DMM with alternatives, when other manufacturing solutions are found to resolve slim jim processing issues.

·         Increase slightly, the minimum paper weight for self mailers to improve machinability.

·         Require two one inch tabs on the top or ends of self mailers.

·         Increase tab size on self mailers to 1 inch.

·         Make sure the industry is able to meet DMM specifications with existing equipment.

·         Do much more testing with industry involvement to evaluate and justify any future changes in the letter mail stream.

·         Do a much better job of enforcing current regulations before adding more complex regulations to the DMM.

 

  

Todd Butler
Butler Mailing Services
513-870-5060

 

 



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