The U.S. Postal Service in late February issued a final rule regarding eligibility for commercial flats failing the deflection or “droop” test.
This final rule, published in the Federal Register, provides revised mailing standards and price eligibility for commercial flats of all classes that don’t meet the deflection standard — or the books that are too floppy to be processed by the postal equipment.
The USPS had relaxed the deflection standards in 2007 by increasing the permitted deflection to up to 4″ for flat-size pieces at least 10″ long. The new deflection standards allow 1″ less of vertical droop. (For more information about the final rule, go to: http://pe.usps.com/FRN/Deflection_final.pdf).
“There is ample evidence that flimsy flat-size pieces that fail to meet deflection standards cannot be processed without incurring many feeding and jamming problems,” the final rule says. “Therefore, we cannot continue to accept those pieces at prices that are based on our ability to process such pieces via automated processing.”
Flat-size pieces that do not meet deflection standards are not currently eligible for any automation flats prices — including full-service Intelligent Mail Barcode pieces. Basic deflection standards take effect June 7, with price consequences effective Oct. 3.
Test too subjective
Several industry watchers have problems with the new droop standards. Hamilton Davison, executive director of the American Catalog Mailers Association, believes the penalties, which range from 25% to 45% of postage paid, are too stiff. The ACMA wants to help the USPS with automation, Davison says, “but it could encourage us to do so with a much smaller penalty.”
And while the USPS has made some changes to make the droop test more objective, “it’s still pretty subjective,” Davison says. What’s more, without having a method to test it accurately before a run, “if a catalog doesn’t pass, what do you do with the millions of printed pieces?” he asks.
ACMA officials have met with the USPS to suggest some ways to make the test more objective. For instance, “we asked for a precertification process,” Davison says, but the Postal Service didn’t want to consider that.
Don Landis, vice president of postal affairs for catalog printer Arandell Corp., agrees that while the new deflection test is better than the original, “it still leaves room to be subjective. I think precertification, with small leeway plus or minus, is the only way to go.”
Why doesn’t the Postal Service want to consider precertification? The USPS says it has a review process for helping catalogers prepare pieces for mailing. “Local acceptance and mail piece design analysts work closely with customers to help them reduce costs or improve machinability,” says USPS spokesperson Yvonne Yoerger.
It’s also important that “live” mail pieces, rather than test catalogs, be reviewed, Yoerger says. There are too many variations during the production process that could affect the final design of a mail piece, she notes: “It’s better for the mailers to have feedback on postproduction pieces.”
The final rule also specifies that most mailers can avoid penalties by changing the design or production of their mail pieces. For instance, Yoerger says, “a different type of paper for the cover, a tab strategically placed, a different type of glue, adding an insert, could all make a piece less floppy.”
But mailers aren’t likely to appreciate this advice, since most measures to make a catalog less floppy — such as thicker or stiffer paper — will add to production costs.
Joe Schick, director of postal affairs for printer Quad/Graphics, says most catalogers should get a better feel for what passes, what fails and what is questionable between June and October.
“We’ll also use the time to ensure that the postal clerks are verifying the mail in the proper manner and doing it consistently across all sites,” Schick adds. “Come October, everyone will have to be ready to comply, because we won’t see another delay.”