Ever since it was published late last month, the Postal Service's proposed rule on booklets and self-mailers has been drawing widespread response from commercial mailers and their clients - and much of that response has been far from supportive.
The Postal Service's proposal, published in the December 29, 2008, Federal Register, reflected the results of mailpiece testing the agency had conducted earlier in the year and its desire to improve mail processing efficiency and reduce equipment jams and mailpiece damage.
Though many in the mailing industry acknowledge the inadequacy of some current mailpiece design standards that apply to what are nominally letter-size booklets ("slim jims"), they don't fully endorse the proposed revisions, either.
Extensive USPS testing may have demonstrated the need for stronger cover stock and better tabs, but industry observers note that the proposed standards include technical specifications that neither they nor postal acceptance personnel can implement or evaluate. Other sources of concern include reductions in the maximum size of booklets, inconsistent cover stock specifications, and rules for tabbing that are objectionable for mailpiece designers and operationally challenging for mail producers.
However, the majority of industry reaction, and the majority of industry discontent, has been with that portion of the proposal pertaining to folded self-mailers.
Unlike for its proposed standards for booklets, the Postal Service did not offer test results, and industry representatives who participated in the agency's testing of booklets reported similar testing was not conducted for folded self-mailers.
As a result, many observers question how the Postal Service could support its proposal for self-mailers when it tested only booklets, and attribute the origin of the self-mailer proposals to zealots in USPS operations and engineering who seem intent on ridding the letter mailstream of anything not in an envelope.
While few in the industry wouldn't support the overall goals of greater USPS efficiency and reduced processing costs, just as few would support pursuing those goals with a strategy that is as single-minded and myopic as trying to drive all letter mail to be more or less identical.
Admittedly, neither the Postal Service nor ratepayers benefit from an inefficient postal system; the cost of processing mail of any design ultimately falls on those who send it. But even the Postal Service understands - to some degree - that mailers' interest in using the mail can be annihilated if an exaggerated focus on efficiency stifles any creative flexibility in mailpiece design, or occasions equally deadening production costs.
Whether the Postal Service has any interest in the industry's concerns, or in changing its proposal to accommodate those concerns, will be demonstrated by the content of its final rule when that is issued in the near future.
This article is based on one that appeared in the January 23 issue of Postal Points, MFSA's postal newsletter.
Leo Raymond is the Vice President, Postal and Member Relations, for the Mailing & Fulfillment Service Association, the only national trade association for the mailing and fulfillment service providers. For more than 87 years MFSA has been working to improve the business environment for mailing and fulfillment companies and to provide their managers with opportunities for learning and professional development. MFSA offers:Instant Postal Information, Periodicals, Surveys, and Manuals unique to the industry, Networking Opportunities, Management Education and Information. The association includes over 600 companies, mostly in the US and Canada. Visit: www.mfsa-net.com.
