[Federal Register Volume 66, Number 103 (Tuesday, May 29, 2001)]
[Rules and Regulations]
[Pages 29031-29040]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-13397]
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POSTAL SERVICE
39 CFR Part 111
Preparation Changes for Securing Packages of Mail
AGENCY: Postal Service.
ACTION: Final rule.
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SUMMARY: This final rule sets forth revised Domestic Mail Manual (DMM)
standards that will help ensure packages of Periodicals and Standard
Mail maintain their integrity during transportation and postal
processing. This final rule reorganizes DMM M020
[[Page 29032]]
by prescribing basic standards for preparing and securing all packages
and incorporating standards that pertain individually to packages on
pallets, packages in sacks, and packages in trays. The most significant
changes, in revised DMM M020.1.8, establish new maximum weight and
height limits for packages of Periodicals and Standard Mail prepared in
sacks. The maximum height (thickness) for Periodicals and Standard Mail
packages in sacks depends on whether the cover or outer surface of the
piece is coated (glossy) or uncoated stock. Packages of pieces with
coated cover stock must not exceed 3 inches in height if secured with
string or twine, rubber bands, or shrinkwrap without an additional
band. However, if packages of coated pieces are secured with a minimum
of two plastic straps or with shrinkwrap plus one or two bands, they
must not exceed 6 inches in height. For pieces with uncoated cover
stock, packages in sacks must not exceed 8 inches in height, although
it is recommended that such packages not exceed 6 inches in height. The
maximum weight for all packages of Periodicals and Standard mail
prepared in sacks is 20 pounds. This limit is consistent with the
maximum weight prescribed for such packages when prepared on pallets
and is the maximum weight of packages or parcels that can be processed
on the small parcel and bundle sorter (SPBS).
EFFECTIVE DATE: July 1, 2001.
FOR FURTHER INFORMATION CONTACT: Cheryl Beller, 202-268-5166,
[email protected].
SUPPLEMENTARY INFORMATION: On February 20, 2001, the Postal Service
published for public comment in the Federal Register (66 FR 10868-
10872) a proposal to require that for Periodicals and Standard Mail
prepared in sacks: [1] packages must not weigh more than 20 pounds as
provided in new DMM M020.1.8a; [2] packages of pieces with covers of
coated stock that are not individually enclosed in an envelope or
protective wrapper (e.g., polywrap or uncoated paper wrapper) must not
exceed 3 inches in height if secured with string or twine, rubber
bands, or only shrinkwrap, and must not exceed 6 inches in height if
secured with two plastic straps or shrinkwrap plus one or two bands as
provided in new DMM M020.1.8d; and [3] packages of pieces with outer
surfaces of uncoated stock must not exceed 8 inches in height, although
it is recommended that such packages not exceed 6 inches in height, as
provided in new DMM M020.1.8e. It was also proposed that the general
packaging standards in DMM M020 be revised by: [1] Eliminating the
required banding sequence in DMM M020.2.3b that the first strap be
placed around the length and the second around the girth when double-
banding packages over 1 inch (redesignated DMM M020.1.4); [2]
requiring, for packages of pieces of nonuniform thickness, counter-
stacking for sacked and palletized mail to create packages of more
uniform thickness as provided in revised DMM M020.1.2; [3] reinforcing
and clarifying the requirement that packages over 1 inch in height,
whether placed in sacks or on pallets, must be secured with at least
two bands, with shrinkwrap, or with shrinkwrap plus one or two bands as
provided in DMM M020.1.4d. The deadline for submitting comments on the
proposal was March 22, 2001.
Part A below summarizes the revisions to the proposal made in this
final rule. Part B sets forth the evaluation of the comments received.
It should be noted that although the DMM refers to individual pieces
secured together as a unit to a single presort destination as a
``package,'' many in the mailing industry refer to these units of mail
as ``bundles,'' and the terms are used interchangeably in the
discussion of comments below.
A. Summary of Revisions to the Proposed Rule
Based on comments received in response to the proposed rule, the
Postal Service is adopting the standards set forth in the proposed rule
with the following changes:
(1) DMM M020.1.2 in the proposed rule has been revised to allow,
rather than require, mailers to counter-stack pieces of nonuniform
thickness to create packages of more uniform thickness, which are more
likely to maintain their integrity during transportation and
processing.
(2) DMM M020.1.5b has been revised in the final rule to eliminate a
required sequence for applying shrinkwrap plus a strap to packages on
pallets. The revised language is consistent with DMM M020.1.4b,
M020.1.8d, and M020.1.8e(2) in this final rule.
(3) DMM M020.1.8f has been revised in the final rule to clarify
that ``uncoated stock'' also refers to pieces with coated covers that
are individually enclosed in a cover or mailing wrapper of uncoated
stock such as an envelope, sleeve, protective cover, partial wrapper,
or polybag, and pieces with outer surfaces composed of material other
than paper (e.g., plastic, cloth, fiberboard, or metal). As such,
packages of such pieces prepared in sacks may be up to 8 inches high
(thick). This section is also revised in the final rule to clarify that
although packages of pieces of uncoated stock may be up to 8 inches
high, it is recommended that such packages not exceed 6 inches in
height.
DMM M020.1.8b in the proposed rule, which repeated general language
already included in M020.1.4, has been deleted from the final rule. DMM
M020.1.8d(3) and M020.8d(4) in the proposed rule contained standards
for measuring packages of pieces with coated cover stock. These
standards were repeated in DMM M020.1.8e(3) and M020.8e(4) for pieces
with uncoated cover stock. Therefore, these items are deleted and their
content, applying to all packages of Periodicals and Standard Mail
prepared in sacks, is redesignated in the final rule as M020.8c and
M020.8d.
B. Evaluation of Comments Received
1. General
Twelve comments were received. All commenters were generally
supportive of the efforts undertaken by the Postal Service and mailing
industry to improve the processing, transporting, and handling of the
mail, and two commenters indicated support for all of the changes in
the proposed rule.
One commenter stated that the problem of broken bundles is not new.
The commenter noted that over the past 15 years, the Postal Service and
outside consultants identified ``root causes'' for bundle breakage but
took no serious actions to resolve the problem prior to the efforts of
the Mailers Technical Advisory Committee (MTAC) Package Integrity Work
Group to collect breakage data for live mail and to conduct a
controlled test for sacked mail. The proposed rule is intended to
address these concerns by updating and clarifying DMM M020 standards.
One commenter representing Periodicals mailers has worked with the
Postal Service to reduce the incidence and costs of bundle breakage. As
part of the Periodicals Operations Review Team and through MTAC, the
commenter and members observed an alarming rate of bundle breakage for
Periodicals and Standard Mail flats and worked with the Postal Service
to understand root causes and identify changes to improve integrity.
One commenter expressed support for the targeted approach to a
cost-effective solution to the bundle breakage problem that will not
overburden publishers and printers and stated that the proposal will
help in the short term. The commenter also believes that a long-term
solution is needed.
One commenter favors cost-effective solutions to the bundle
breakage
[[Page 29033]]
problem and wants the Postal Service to capture savings identified in
conjunction with the Periodicals Operations Review Team in the recent
rate case, but believes the proposed changes could potentially impose a
huge financial burden on customers.
One commenter representing smaller-volume Periodicals publications,
with circulation generally under 100,000 and mailings prepared
primarily in sacks rather than on pallets, recognizes bundle breakage
is a problem. This commenter is concerned that the proposed rule ``is a
costly (to mailers) stopgap measure that may not be effective in
accomplishing its stated purpose of reducing USPS handling costs'' but
expects the proposal to be implemented and members to adapt. This
commenter also believes that additional steps the Postal Service is
taking, such as educating mailers, improving induction methods, and
enabling customers to prepare flats in a manner that supports
processing on flat sorting machines (FSMs), are more likely than the
proposed changes to cause a meaningful change in processing costs.
The Postal Service and mailing industry have been working together
on several fronts to address the serious issue of bundle breakage and
its associated costs, which are ultimately reflected in postal rates.
As noted, this problem is not new and this final rule is but one of
several ongoing efforts to make long-needed changes that will have an
overall positive effect on bundle breakage and flats processing costs
and efficiencies in general. The MTAC Package Integrity Work Group was
created to address the bundle breakage problem identified by the
Periodicals Operations Review Team. This final rule represents one step
toward achieving incremental improvements while long-term solutions are
explored. Various concerns raised by commenters about specific
provisions of DMM M020 that are contained in the proposed rule are
described and responded to below.
2. Counter-Stacking
Two commenters questioned whether the proposed requirement to
counter-stack pieces of nonuniform thickness to create packages of more
uniform thickness will increase carrier and clerk costs to re-orient
the pieces before sorting them by a greater amount than the savings
that might result from reduced bundle breakage costs.
One commenter requested further clarification of the situations
that would require counter-stacking to avoid different interpretations
by acceptance personnel and mailers. It was suggested that a clearer
definition of ``non-uniform thickness'' be provided, possibly including
a measurement, such as ``if there is more than .25" difference in
thickness from top to bottom (thinnest to thickest).''
Based on the comments and upon further review of this issue, the
Postal Service has determined that re-orienting counter-stacked pieces
to prep flats for delivery or to run on a flat sorting machine (e.g.,
an AFSM 100) is time consuming and, in many situations, may add to
processing costs. Because it is difficult to describe objectively each
situation when it would be appropriate to counter-stack pieces to
maintain package integrity, M020.1.2 in this final rule has been
revised to recommend, rather than require, counter-stacking to create
more uniform packages. In addition, language has been added to clarify
that mailers should limit the use of counter-stacking to those
situations when it is expected to actually improve the uniformity and
stability of a package. For example, some postal processing facilities
have reported that they receive packages from mailers as small as 1
inch high that contain three or four counter-stacked groups. These
small counter-stacked groups have little, if any, impact on the
integrity of the package and make it difficult for postal personnel to
re-orient the mail to run on a flat sorting machine or for delivery.
3. Twenty-Pound Maximum Weight for Packages in Sacks
Two commenters expressed their approval of the proposal to limit
the weight of Periodicals and Standard Mail packages prepared in sacks
to 20 pounds and noted that packages that exceed this weight contribute
to bundle breakage and cannot be processed on the SPBS. Furthermore,
one commenter stated that the 20-pound maximum for packages in sacks is
neither unreasonable nor burdensome and is consistent with the standard
for packages on pallets.
The 20-pound maximum package weight is retained in this final rule.
4. Requirement to Shrinkwrap Packages on Bulk Mail Center (BMC) Pallets
Two commenters indicated that mailers could move more Standard Mail
out of sacks and onto pallets, and thereby reduce package breakage
rates for this mail, if they were permitted to use banding instead of
shrinkwrap to secure packages on BMC pallets. One commenter noted that
the processing of bundles on BMC parcel sorting machines (PSMs) is
abusive and normal packaging may not withstand this processing and
recommended that the Postal Service identify the BMCs that do not
process bundles on their PSMs. Mailers should then be permitted to use
banding instead of shrinkwrap for bundles on BMC pallets sorted to
those facilities.
One commenter secures packages of Standard Mail with bands around
the length and girth and reported receiving few if any complaints about
breakage. This mailer must sack mail that remains after 5-digit and SCF
pallets are prepared because of the requirement to shrinkwrap packages
on BMC pallets. These sacks are often placed on BMC pallets. This
commenter indicated that most letter shops do not have the ability to
shrinkwrap packages and could move approximately 80 percent of packages
currently prepared in sacks onto pallets if the Postal Service would
allow banded packages on BMC pallets.
In conjunction with other efforts focused on moving mail out of
sacks to reduce the potential for package breakage and the costs
associated with such breakage, the Postal Service will explore
potential opportunities to place packages secured with material other
than shrinkwrap onto BMC pallets. However, before any final decision is
made, the impact that such a change could have on processing costs and
service must be fully evaluated. For example, candidate packages may
currently be in carrier route-through ADC-level sacks and some analysis
would be required to determine the potential difference in container
and package handling costs if these packages were to move out of more
finely sorted sacks and onto BMC pallets. The Postal Service must also
assess the potential impact on package breakage rates resulting from
more package handlings but fewer sack handlings, particularly for
carrier route, 5-digit, and 3-digit packages, and how this could affect
service considering that the recovered pieces must generally be
transported to the parent plant for appropriate piece distribution
(e.g., on a flat sorting machine). Finally, the methods used by BMCs to
process packages on BMC pallets must be reviewed to determine if
service would be negatively impacted when compared to the service the
mail would receive if prepared in sacks. Sacked mail is processed by
BMCs to plants or delivery units where the contents of the sacks are
distributed (e.g., are packages at BMCs processed on parcel sorting
machines or SPBSs; what sort schemes are used). If a decision is made
to expand the type(s) of package securing methods that are acceptable
for mail on BMC pallets, it is possible that the standards could be
somewhat more restrictive than the current standards for
[[Page 29034]]
mail prepared on pallets. For example, because data collected by the
MTAC Package Integrity Work Group during live mail tests showed that
mail secured with rubber bands had the highest breakage rates for
palletized packages (2.1 percent), restrictions could be placed on this
type of mail. In summary, no changes to the standards for packages on
BMC pallets are included in this final rule.
5. Clarification of ``Uncoated Stock''
Two commenters requested that proposed DMM M020.1.8d be reworded to
clarify that ``uncoated'' pieces that may be prepared in packages up to
8 inches high includes pieces with coated covers that have been
enclosed in a protective cover or mailing wrapper as described in DMM
C200.1.7. One commenter asked that the Postal Service clarify that
individually polywrapped pieces fall into the category of ``uncoated''
pieces, whether or not the pieces inside the wrapper have coated
covers.
This final rule clarifies in DMM M020.1.8e that the term ``uncoated
stock'' includes pieces with coated covers that are individually
enclosed in a cover or mailing wrapper of uncoated stock such as an
envelope, sleeve, protective cover, partial wrapper, or polywrap, and
also includes pieces with outer surfaces composed of material other
than paper (e.g., plastic, cloth, fiberboard, or metal). The final rule
also specifies that packages of such pieces must not exceed 8 inches in
height.
6. Maximum Height of Packages of Uncoated Pieces
One commenter prepares Periodicals that have a low height-to-weight
ratio in firm bundles that are shrinkwrapped and strapped. These
bundles may occasionally exceed the proposed uncoated pieces maximum
package height of 8 inches, possibly reaching 10 inches in height. The
mailer has not received any feedback about broken bundles and requests
that the maximum height for uncoated packages in sacks be raised from 8
inches to 10 inches. If the maximum height will not be raised,
clarification was requested as to whether current DMM M020.1.6a
(redesignated as M020.1.7a in this final rule) allows payment of one
piece rate if two firm bundles are created to avoid exceeding the
maximum height limit. In addition, this commenter asked that the final
rule include a clarification of the difference between the recommended
maximum height of 6 inches and the required maximum height of 8 inches
for packages of uncoated pieces prepared in sacks.
The Postal Service believes that concerns about bundle integrity
and successful SPBS processing are compelling reasons to limit the
maximum height of packages of uncoated pieces in sacks to 8 inches. The
20-pound maximum weight ensures packages are compatible with SPBS
processing and it is likely that most packages that exceed 8 inches,
when measured at the lowest point as permitted by the new standards,
would also exceed 20 pounds. Exceptions are likely to be pieces similar
to the DVDs in plastic containers that were included in the controlled
test that are less dense than printed material, including circulars,
magazines, newspapers, catalogs, and so forth. When such lightweight
but thick items are prepared in tall packages (e.g., packages taller
than 8 inches), the packages are more likely to break during
transportation or processing or to lean and tumble into the wrong
container as they are sorted on the SPBS.
The maximum package height of 8 inches for packages of uncoated
pieces prepared in sacks is retained in this final rule. DMM
M020.1.8.f(1) has been revised to consolidate the maximum permitted
height of 8 inches and the recommended maximum height of 6 inches for
packages of uncoated pieces prepared in sacks. We believe that this
will clarify that such packages may be up to 8 inches in height but the
Postal Service wants to encourage mailers to limit these packages to a
maximum height of 6 inches. This recommendation is intended to help
ensure that bundle integrity will be maintained while recognizing that
some mailpieces can be prepared in taller packages (e.g., up to 8
inches high and weighing up to 20 pounds) that can be successfully
processed by the Postal Service.
If a firm bundle must be split in two to meet the new height
restrictions, each firm bundle is subject to a separate per piece
charge to reflect the handling of two pieces by the Postal Service. For
purposes of rate eligibility, pieces prepared as one firm bundle under
current standards that must be prepared as two firm bundles due to the
height restrictions in this final rule would pay two per piece charges,
reflecting the fact the Postal Service is processing and delivering two
pieces. Under DMM M020.1.6a (redesignated M020.1.7a) these would also
count as two addressed pieces in determining whether there are six or
more pieces to a presort destination when determining Periodicals rate
eligibility.
7. Coated Stock and Breakage
Two commenters agreed that coated stock does contribute to package
breakage. One stated that there is no question that pieces with coated
cover stock contribute to bundle breakage and that it makes sense to
reduce the maximum height to 6 inches for banded or strapped bundles.
One commenter confirmed that the highest breakage rate occurred for
sacked flats with glossy covers of coated stock, and bundles 4 to 6
inches high broke 42 to 100 percent of the time in the MTAC Package
Integrity Work Group controlled test, before the bundles were even
handled individually. This commenter stated that these high breakage
rates ``cause significant costs (in the form of additional piece
handlings and machine slowdowns and stoppages) borne by all mailers of
flats.'' In the controlled test, adding a plastic strap to
shrinkwrapped packages reduced the breakage rate by 25 percent;
packages with two plastic straps had a breakage rate 15 percent lower
than the rate for shrinkwrapped packages; and reducing the size of
packages by 1 inch reduced breakage by approximately 14 percent.
The key focus of this final rule is to reduce breakage rates for
packages of pieces with coated cover stock.
8. Impact of Limiting Package Height
Seven commenters stated that the proposal to limit, for Periodicals
and Standard Mail in sacks, the size of packages of pieces with coated
stock secured with rubber bands, string or twine, or shrinkwrap without
a band to 3 inches in height will increase the number of packages that
some mailers will prepare.
One commenter stated that the creation of more packages will add to
Postal Service mail processing costs, which is not in the best
interests of the mailing industry or the Postal Service, and another
stated that the proposed rule could increase by nearly 5 percent the
number of bundles that one of its members produces.
One commenter suggested that the proposal will cause mailers to
prepare a greater number of packages that are more difficult to open,
which will change processing costs. The commenter also stated they
would be more positive about the changes if the Postal Service had
attempted to quantify added costs associated with the additional
packages, such as those related to Postal Service-allied labor costs
for opening packages and prepping mail for automated flat sorting
machines.
[[Page 29035]]
One commenter noted that a Postal Service representative had stated
that ``over 30 percent of the USPS handling and processing costs for
flats were depackaging'' and that the proposal would be contrary to the
objective of creating fewer packages as well as fewer sacks. This
commenter also stated that preparing smaller packages secured only with
shrinkwrap for sacked mail will slow production and add to mailer
costs. The mailer will need to have list processors provide bundle
separation marks for production lines that do not have an ``auto slow
down'' control to maximize bundle size and machine speed. For one
customer, some packages for sacked mailings may contain as few as two
pieces to meet the 3-inch height limit.
One commenter questions whether the Postal Service documented or
measured the cost of handling the additional packages that will be
produced if the proposed changes are adopted and asks if the Postal
Service has a metric to ensure that the cost reductions for breakage
materialize as a result of the proposed rule.
Analysis of the MTAC Package Integrity Work Group test data shows
that reducing the size of ``high-risk'' packages, specifically packages
of pieces with coated cover stock prepared in sacks, will result in
significant savings. In the controlled package integrity test, the
workgroup found that 75 percent of 4-inch and 6-inch packages of coated
pieces entered at an origin facility broke even before the packages
were handled individually out of the mailer-prepared sacks. Based upon
additional analysis of test data for both the live mail and controlled
tests, the Postal Service believes that cutting the size of a large
package of coated flats in half would reduce bundle breakage for the
affected mail by approximately 50 percent.
Using the same methodology that the Postal Rate Commission (PRC)
used in Docket No. R2000-1 to analyze this cost trade-off, we found
that cutting the average package size for Periodicals and Standard Mail
high-risk flats in half (e.g., from an average of 20 down to 10 pieces
per package and from 15 down to 7.5 pieces per package) may reduce
average mail processing costs for these flats by as much as 0.4 to 0.7
cents per piece. Furthermore, the PRC's methodology does not take into
account reductions in allied labor costs that may result from reduced
package breakage. The focus of this final rule is to significantly
reduce package breakage using current packaging methods. It is not
expected that packages prepared by mailers will be any more difficult
to open as a result of these changes. It is expected, as noted
previously, that the Postal Service will have to process some
additional packages that are more likely to maintain their integrity
and that packaging in general for mail prepared both in sacks and on
pallets will improve as mailers use current methods more effectively.
The Postal Service does not have a metric to ensure that the
projected cost reductions materialize as a result of this final rule.
After this final rule has been in effect for several months, in order
to quantify whether package breakage rates have decreased, the Postal
Service plans to collect additional data for live mail in the same
manner as originally collected by the MTAC Package Integrity Work Group
in 1999.
9. Clarification of Rate Eligibility
One commenter stated that because of the 3-inch package height
maximum for some mail, packages of large Periodicals publications could
sometimes contain fewer than six pieces. This commenter requested that
the final rule clarify that rate eligibility standards for such
packages will be satisfied as long as there are a minimum of six
addressed pieces for the presort level, even if they are prepared in
more than one physical package due to the maximum height limit.
Under the provisions of current DMM M020.1.6a, an individual
package may be prepared with fewer than the minimum number of pieces
required by the standards for the rate claimed without loss of rate
eligibility if a greater number of pieces would exceed the maximum
physical size for a package and the total number of pieces for that
presort destination meets the minimum volume standard (e.g., 30 pieces
are available to meet a 10-piece minimum, but a package of eight pieces
is 6 inches thick). In the proposed rule, this section was redesignated
as M020.1.7, but was not printed. The complete contents of redesignated
M020.1.7 are published in this final rule to clarify that rate
eligibility for smaller packages prepared under the new height limits
is based on the total number of pieces for the presort destination.
10. Strappers
Seven commenters indicated that many printers use only shrinkwrap
to secure packages and have removed strapping from most of their
production lines. Three commenters stated that this allows lines to run
faster, more efficiently, and is less costly and that adding strappers
to their lines would be expensive.
One commenter stated that most of its mail is sacked due to volume
and densities of publications and most mail is also of coated stock.
This mailer would choose the option of reducing package size to a 3-
inch maximum height instead of adding strapping equipment but is
concerned that it will add costs by slowing bindery mailing equipment
production speeds, adding material, and increasing labor. Because of
the competitive market, the mailer would have to absorb additional
costs and would like instead to test heavier shrinkwrap that could be
used without an additional strap on packages over 3 inches that are
prepared in sacks. This would add some material costs but less than
those resulting from the proposed changes. This commenter indicated
that the alternative of adding additional strapping equipment that
would permit larger packages would require a capital investment of over
$500,000 for the strappers and building expansions to accommodate the
additional equipment. Currently, this mailer uses only banding to
secure packages of individually polywrapped pieces. This commenter also
suggested that the Postal Service allow a variety of packaging methods
as long as mailers first submit packages for testing and approval.
One commenter stated that instead of adding strappers, the maximum
package height would be reduced and the added cost for changing the
size of some packages would be approximately $250,000. The commenter
prepares sacks and pallets and could set the parameters for only their
sacked mail to a maximum package height of 3 inches. For some mail,
this could double the number of packages and impact their costs and
productivity. This commenter suggests that the Postal Service, in
conjunction with the printing industry, test and determine formulations
and mil strength of polyfilm that could be used instead of an
additional strap to secure packages of coated pieces that are taller
then 3 inches.
One commenter stated it would have to spend millions of dollars to
purchase and install new strappers and would lose millions of dollars
in maintenance, downtime, and lower productivity. It requested that
mailers be given the option of selecting the securing method they
prefer that makes the most sense for their operation and their
customers.
One commenter stated that additional strapping requirements will
add to printers' and publishers' mail preparation costs and the Postal
Service must capture savings from the proposed standards or the change
will have a net negative impact on publishers and printers.
One commenter suggested that, as a next step, they would like to
test heavier
[[Page 29036]]
shrinkwrap (e.g., 2 to 3 mils) or high-performance formulations that
may be substituted for the addition of a strap to shrinkwrapped
packages or bundles of glossy mail in sacks that exceed 3 inches. This
commenter stated that most of the mailing industry uses film that is
1.25 to 1.5 mils thick.
One commenter stated that prohibiting packages of pieces with
coated stock that exceed 3 inches unless they are double-strapped or
strapped with shrinkwrap is burdensome and may be unreasonable because
printers have moved away from strapping to shrinkwrap. The best
solution may be to require heavier shrinkwrap.
The Postal Service developed the proposed rule in conjunction with
a joint Postal Service/industry effort to reduce package breakage and
lower Postal Service operational costs by improving mailer packaging
and Postal Service processing of such mail. Data describing the current
condition of packages of Periodicals non-letters and Standard Mail
flats was collected and analyzed by the workgroup to identify changes
that could be made to achieve these results. MTAC workgroup members
generally agreed that an analysis of test data clearly pointed to a
need to either improve the methods for securing tall packages of pieces
of coated stock or reduce the size of such packages if securing methods
are not improved. Workgroup members included major mailers that have
eliminated banding from most of their production lines and whose
operations will be impacted by these changes. These participants
indicated that they did not expect their companies to purchase new
strapping equipment that would allow them to create 6-inch packages of
coated pieces. Instead, they were likely to use current packaging
materials, such as shrinkwrap, and to limit the height of packages of
coated pieces to be placed in sacks. Several of these participants
indicated that many major mailers use shrinkwrap material that is from
0.75 to 1.25 mils thick to secure palletized and sacked packages and
that, based on test data, this polywrap is not effective without the
addition of a strap in maintaining the integrity of tall packages of
coated pieces when they are prepared in sacks. There was also general,
although reluctant, agreement that the test data suggested that the
proposed packaging changes probably offered the best near-term
potential to achieve cost savings from reduced package breakage for
mail in sacks. However, other efforts currently under way to move more
mail out of sacks and onto pallets, to improve Postal Service
processing of packages, and to find alternatives to current preparation
methods were seen as offering the greatest long-term potential to
reduce the costs associated with package breakage. While the Postal
Service will continue pursuing these other efforts, we do not believe
that we can afford to delay steps that eliminate from the sacked mail
environment those packages that have been clearly identified as the
most likely to break.
Some perspective on what might be involved in establishing a
certification program for packaging materials and methods can be gained
by looking at the development of the process that led to the current
standards for certifying polywrap films for automation rate flats. The
Postal Service believes that a program to certify packaging materials
and methods could be even more complex and costly to implement because
of the many variables related to package contents (mailpiece
characteristics) and size that would have to be tested at many mailer
locations using a broad range of packaging materials and securing
methods. At this time, the Postal Service does not have resources to
apply to such an effort and believes that the combination of efforts to
reduce package breakage currently under way, including better feedback
to customers when package integrity problems are identified during
postal processing, offer the most promise for improvements.
The Postal Service is open to future discussions regarding industry
testing and recommendations for some specific polyfilm formulations
that may be used successfully for taller, heavier packages of pieces of
coated stock. In assessing alternatives to the materials used today by
large printers who probably prepare the majority of their mail on
pallets, the overall cost of applying this material to packages on
pallets as well as in sacks must also be considered. If mailers were to
use a heavy polyfilm that maintains the integrity of the worst mail
they produce (i.e., tall packages of coated pieces in sacks) on all of
their mail, including mail on pallets, mailer application costs and
Postal Service removal and disposal costs could also increase.
To mitigate the impact of this final rule on overall costs, mailers
who prepare both palletized and sacked mail need to set different
package height maximums for each type of mail when presorting their
mailing lists. Several major presort software vendors have stated that
their software provides users with the ability to do this.
11. Sequence for Material Application
One commenter has strappers in some processes that apply a single
strap around the girth of a package due to package size or an off-
balance bind on the mailpiece. The strap is applied after the
shrinkwrap, and the commenter therefore suggests that DMM M020.1.5b
read ``Packages may be secured with heavy gauge shrinkwrap AND plastic
banding, only shrink wrap, or only banding material if they can stay
together during normal processing.'' The proposal in DMM M020.1.5b
stated that ``Packages may be secured with heavy-gauge shrinkwrap OVER
plastic * * *rdquo;.
To be consistent with DMM M020.1.4b, M020.1.8d, and M020.1.8e(2),
the language in M020.1.5b has been changed in this final rule to
eliminate a required sequence for applying shrinkwrap plus a strap to
packages on pallets.
12. Flat Trays or Other Containers as an Alternative to Sacks
Three commenters stated that the Postal Service must identify a
container that can be used instead of sacks for mail that cannot be
placed on pallets.
One commenter noted that the Postal Service must urgently pursue
alternatives to sacking for those short-run publications that have
insufficient density or volume to be palletized. These publications
must be placed in sacks, which creates added costs at printers and
results in damage from handling by the Postal Service. This commenter
stated that some Periodicals have moved from sacks to cartons on
pallets under local arrangements.
One commenter encourages the Postal Service to develop a cost-
effective alternative to sacking that is compatible with the flats
automation strategy for small volume mailers who may not be able to
palletize.
One commenter stated that mail secured with straps and placed in
sacks often becomes damaged when entered into the SPBS system by being
crushed by other mail. Crushing can create broken bundles and also make
the pieces incompatible with Postal Service automated flat-sorting
machines. This commenter also stated that removing banding from bundles
can be dangerous to USPS employees and that for these reasons mailers
should be permitted to place Periodicals and Standard Mail flats in
flat trays instead of sacks, preferably unbundled in a tray-based
preparation like that currently offered for First-Class Mail. This
commenter also suggested that placing flats in trays that can be
palletized and are
[[Page 29037]]
compatible with Postal Service tray management systems (TMS) will save
costs by eliminating processing of bundles on the SPBS and making flats
more compatible with processing on the AFSM 100 or FSM 1000. The Postal
Service could limit transportation and handling of these trays by
permitting them only for palletized mail drop shipped by mailers to
specified entry levels.
The Postal Service must evaluate the broad impact of a move from
sacks to flat trays or another type of alternate container for
Periodicals non-letters and Standard Mail flats. The potential for
improved package integrity must be weighed against many other factors.
In moving from sacks to flat trays, we would expect to see a decline in
cube utilization. Compared to packages of flats prepared on pallets or
in sacks, flat trays often contain a significant amount of unused space
within and between trays for both mailers/consolidators and the Postal
Service. For example, a thin Periodical with 24 pieces to a destination
placed in a flat tray might result in a tray that is only one-quarter
full. For mail that must be transported beyond the origin plant service
area, this reduced cube utilization is likely to result in less volume
per vehicle and increased costs.
Another consideration is the processing of containers sorted to
destinations outside of the service area of the origin plant.
Currently, sacked mail is processed efficiently through the BMCs on the
sack sorter machines (SSMs), and sufficient SSM capacity exists. Flat
trays, however, are sorted manually in the BMCs, and if sacks converted
to trays this processing operation could quickly become a bottleneck
due to lower productivity, less depth of sort, and greater space
requirements, again increasing costs.
For some Periodicals and Standard Mail there would not be a one-to-
one trade-off of sacks for trays. For example, mail for one presort
destination that today fills a sack may have to be placed in two trays.
This change would increase the number of container handlings and
associated costs.
There is also the issue of lack of flat tray availability given the
increased demand for flat trays to accommodate incoming secondary
processing on the AFSM 100s. The Postal Service does not have money in
its budget to purchase additional large quantities of flat trays for
mailers to use instead of sacks.
Finally, offering a tray-based preparation option for Periodicals
and Standard Mail with an optional 5-digit sort (mirroring the current
option for First-Class flats) would significantly increase the volume
requiring incoming primary piece processing to sort mail to the 5-digit
level on the AFSM 100s and FSM 1000s. This volume was not anticipated
in the equipment deployment and additional flat sorting machines would
need to be purchased and deployed to handle the additional incoming
primary volume.
The Postal Service recognizes that there may be some future
opportunities to explore alternatives to sacks in some situations;
however, this final rule does not contain any changes to current
sacking requirements.
13. Alternate Flats Preparation Test
Six commenters indicated that they are aware that the Postal
Service is exploring alternate mail preparation for flats to reduce or
eliminate packaging of palletized mail to reduce Postal Service costs.
One commenter suggests that alternate preparation could reduce the
bundle breakage problem in addition to reducing allied labor costs
associated with opening packages.
One commenter who is participating in the test stated that mailers
do not want to make capital investments to improve packaging now when
investments may be required in the near future for different
preparation methods. Another test participant does not think it would
be prudent to make major capital investments in bindery packaging and
material handling equipment until the Postal Service flats automation
strategy is finalized.
One commenter stated that the Postal Service should examine whether
a ``bundle-less'' preparation, such as that being tested for pallets,
could be extended to sacked mailings.
The Postal Service is partnering with the mailing industry to test
methods for preparing flat-sized mail in a manner that best supports
current and future flats processing and is examining the potential cost
savings opportunities of eliminating or reducing packages on pallets.
The test parameters were announced in the February 22, 2001, issue of
the Postal Bulletin. It is because of the many other efforts, such as
the alternate flats preparation test, currently under way to improve
flats processing that the Postal Service is implementing this final
rule. Because new or modified manufacturing processes may prove to be
justified in the future, the revised standards were designed to reduce
overall costs now without requiring mailers to change their
manufacturing methods, and all current methods of securing packages
will continue to be acceptable.
14. Maximum Package Weight as Proxy for Maximum Height
One mailer indicated that presort software currently controls
package size by weight, not height, and the Postal Service should
develop a standard weight-height conversion table that allows mailers
to comply with the proposed rule by using weight as a proxy for height.
This flexibility would facilitate compliance in the shortest time frame
with less disruption to the industry.
The data collected relating to bundle breakage in the live mail
test and the resulting proposed standards do not include information to
correlate height to weight. Although some data is available from the
controlled test to develop a height-to-weight relationship, it would
apply only to the test pieces. It is difficult to develop a standard
conversion chart that would consistently result in packages meeting the
proposed height standards due to the variations in size, composition,
method of binding, paper stock, inserts, and so forth for flat-size
mail. For example, packages of a dense perfect-bound publication
printed on heavyweight coated paper are likely to have a very different
weight-to-height relationship than packages of an enveloped piece
containing a lightweight bulky insert. It would be more feasible and
useful for mailers to use actual sample mailpieces representing their
regular mix of mail to create their own weight-to-height conversion
tables. Presort software does have the ability to control package
height using the thickness of an average piece. This final rule
contains only maximum height standards for packages of Periodicals and
Standard Mail prepared in sacks.
15. Clarification of ``Football-Shaped'' Packages
One commenter questioned whether the 9 inch by 12 inch envelopes in
the controlled test were considered to represent the norm for enveloped
flats. This mail experienced an approximate 58 percent breakage rate
due to an insert in the center that caused the larger packages to
become shaped like a football.
No conclusions were drawn regarding how representative the test
piece might be of the general flats mailstream. The only conclusion
that was drawn was that counter-stacking is unlikely to create stable
tall packages of pieces that are thicker in the center than they are on
the edges and mailers may instead need to limit the package size of
such
[[Page 29038]]
pieces or add additional banding to the packages.
16. Pallets
Three commenters discussed potential opportunities for moving more
mail from sacks to pallets.
One commenter indicated that preparing lighter-weight pallets,
(e.g., 150 pounds) would help move mail out of sacks, while another had
mixed feelings about preparing lighter-weight pallets as a solution for
eliminating sacks. Although 250-pound pallets may result in deeper
penetration and better delivery for some mail, they may cause staging
problems in plants and extra material handling.
One commenter suggested a 5-digit pallet discount to encourage mail
on direct 5-digit pallets that are low cost for the Postal Service.
These direct pallets would also substantially reduce the likelihood of
bundle breakage. The commenter noted that Postal Service rate case
witnesses considered the proposal premature but ``did indicate a
general interest . . . in encouraging palletization and a specific
interest in having additional direct pallets.'' Because the MTAC
Package Integrity Work Group, during its live mail test, found packages
in sacks broke more than 10 times as frequently as packages on pallets,
the commenter suggested that the Postal Service investigate ways to
modify postage rates and mail preparation standards to encourage
mailers to increase palletization. Furthermore, standards should be
considered to allow residual mail, currently in sacks, to be merged
onto pallets. Bundle breakage is strongly related to the number of
handlings a bundle receives. Bundles on more finely presorted pallets
will receive fewer handlings and mailers should be encouraged to
palletize and drop ship pallets.
As noted above, there is a difference of opinion within the mailing
industry as to whether the pallet minimum should be lowered. The DMM
currently contains provisions that allow mailers to prepare pallets
that weigh less than 250 pounds when those pallets are drop shipped to
the destination sectional center facility (DSCF) or destination
delivery unit (DDU). Mailers need to obtain written authorization from
the processing and distribution manager of the entry facility for DSCF
entry of lightweight pallets. There are no data showing that lowering
the minimum pallet weight for mail that is not drop shipped to these
destinations would provide the Postal Service with savings that offset
the additional costs resulting from increased pallet handlings and
decreased cube utilization on postal transportation. There are no plans
at this time to lower minimum pallet weights.
The pursuit of a discount for mail on 5-digit pallets is beyond the
scope of this rule. Any request for domestic rate changes must be
submitted by the Postal Service to the Postal Rate Commission.
Mailers should note that several options currently available have
been shown to increase palletization levels. For example, mailers may
choose not to prepare optional 3-digit pallets or, if they do prepare
such pallets, they may use package reallocation to protect the SCF
pallet level if their software is PAVE-certified to support this
option. In addition, mailers might consider lowering the minimum pallet
weight, possibly to as low as 250 pounds, for only their last pallet
level (e.g., ADC for Periodicals or ASF/BMC for Standard Mail) to keep
mail from falling to sacks. The Postal Service is aware that many
mailers do not take advantage of these opportunities.
17. Improvements to SPBS Feed Systems
Two commenters commended the Postal Service for its efforts to
reduce stress on bundles through equipment modifications. One commenter
encouraged a continued search for gentler handling processes, such as
those associated with the SPBS feed systems, while the other supported
Postal Service efforts to improve package sorting related to SPBS feed
systems as a means to avoid rehandling costs.
In addition to changes to the SPBS feed systems to mitigate bundle
breakage, the Postal Service has modified broken bundle recovery
methods to reduce costs. A new Automatic Package Processing System
(APPS), the next generation SPBS, is also being developed. This new
machine is designed to take bulk-loaded parcels or bundles and separate
them into an evenly spaced singulated stream for scanning and sorting.
This process should be more gentle to flats bundles. However,
regardless of changes to Postal Service processing, mailers must take
necessary steps to ensure that bundles retain their integrity to the
point where they are unloaded on postal processing equipment and opened
for distribution of the contents.
18. Feedback
One commenter stated that the Postal Service has not done a good
job of notifying mailers when packages were improperly prepared and
fell apart during processing. If mailers had been informed regularly of
problems, they could have incorporated packaging alternatives or fine-
tuned methods over time that would not be as costly as the proposed
changes.
The MTAC Mail Irregularity Feedback Work Group was formed in
response to comments that the MTAC Package Integrity Work Group
received from customers indicating that they were not receiving
feedback about broken bundles and therefore were unaware of problems or
any need to change their packaging methods. In order to improve the
quality of business mailings, the Postal Service is revising the
irregularity reporting and correction process. More information about
these changes, including the revised PS Form 3749, Mail Irregularity
Report, can be found in Postal Bulletin 22043 (2-8-01) and in the
February 2001 Memo to Mailers. This process will be used to report
serious quality issues such as broken bundles, unreadable barcodes,
mislabeled trays, and so on, to mailers and mail preparers and also
includes a mechanism to address disposition of reported problems.
19. Implementation Date
One commenter indicated that some changes in the proposed rule
require software programming changes. This mailer requires 45 to 60
days to program and test new enhancements that allow different package
sizes for sacked and palletized mail and proposed an effective date
some time between July 15 and September 1, 2001.
Based on the comments received and discussions with other mailers
and presort software vendors regarding implementation of software and
manufacturing changes to accommodate the final rule, the Postal Service
has determined to place all provisions of this final rule into effect
on July 1, 2001.
List of Subjects in 39 CFR Part 111
Administrative practice and procedure, Postal Service.
For the reasons discussed above, the Postal Service hereby adopts
the following amendments to the Domestic Mail Manual, which is
incorporated by reference in the Code of Federal Regulations (see 39
CFR Part 111).
PART 111--[AMENDED]
1. The authority citation for 39 CFR part 111 continues to read as
follows:
Authority: 5 U.S.C. 552(a); 39 U.S.C. 101, 401, 403, 404, 414,
3001-3011, 3201-3219, 3403-3406, 3621, 3626, 5001.
2. Revise the following sections of the Domestic Mail Manual as set
forth below:
[[Page 29039]]
M Mail Preparation and Sortation
* * * * *
M020 Packages
1.0 BASIC STANDARDS
[Amend 1.1 by replacing the reference to 1.6 with 1.2 to read as
follows:]
1.1 Facing
Except as noted in 1.2, all pieces in a package must be ``faced''
(i.e., arranged with the addresses in the same read direction), with an
address visible on the top piece.
[Amend the heading of 1.2 and revise the text to clarify when
counter-stacking of pieces of irregular thickness is appropriate to
read as follows:]
1.2 Counter-Stacking--Sacked and Palletized Mail
Packages of flats and other pieces of nonuniform thickness may be
prepared by counter-stacking under these conditions:
a. Counter-stacking should be used only to create packages of more
uniform thickness that are more likely to maintain their integrity
during transportation and processing.
b. Counter-stacking is appropriate for saddle-stitched mailpieces
and pieces where one edge is thicker than other edges or one corner is
thicker than other corners.
c. When counter-stacking, pieces must all have addresses facing up
and be divided into no more than four approximately equal groups, with
each group rotated 180 degrees from the preceding and succeeding
group(s); prepare as few groups as possible to create a bundle of
uniform thickness.
d. Counter-stacked groups within a package should be as thick as
possible, generally at least 1 inch thick.
e. When pieces are nonuniform in thickness because they are thicker
in the center instead of along an edge or corner, counter-stacking will
generally not result in a package of uniform thickness (i.e., a
football-shaped package would be created). Instead of counter-stacking
such pieces, limit the height (thickness) of the package to 3 to 6
inches to ensure the package will stay together during normal transit
and handling.
* * * * *
[Redesignate 1.4, 1.5, and 1.6 as 1.5, 1.6, and 1.7, respectively,
and add new 1.4 to read as follows:]
1.4 Securing Packages--General
Package preparation is subject to the following requirements:
a. Packages must be able to withstand normal transit and handling
without breakage or injury to USPS employees.
b. Packages must be secured with banding, shrinkwrap, or shrinkwrap
plus one or more bands. Banding includes plastic bands, rubber bands,
twine/string, and similar material. Use of wire or metal banding is not
permitted.
c. When one band is used, it must be placed tightly around the
girth (narrow dimension).
d. Except under 1.5 and 2.1f, packages over 1 inch high (thick)
must be secured with at least two bands or with shrinkwrap. When double
banding is used to secure packages, it must encircle the length and
girth of the package at least once. Additional bands may be used if
none lies within 1 inch of any package edge.
e. Banding tension must be sufficient to tighten and depress the
edges of the package so pieces will not slip out of the banding during
transit and processing. Loose banding is not allowed.
f. When twine/string is used to band packages, the knot(s) must be
secure so the banding does not come loose during transit and
processing.
[Amend the heading of redesignated 1.5, add new 1.5a, and
redesignate the current content as 1.5b to read as follows:]
1.5 Packages on Pallets
In addition to 1.1 through 1.4, packages on pallets must meet the
following standards:
a. Except as noted in 1.5b, packages up to 1 inch in height
(thickness) must be secured with appropriate banding, placed at least
once around the girth, or with shrinkwrap. Packages over 1 inch in
height must be secured with at least two bands (plastic bands, rubber
bands, twine/string, or similar material), one around the length and
one around the girth, with shrinkwrap, or with shrinkwrap plus one or
two bands.
b. Packages may be secured with heavy-gauge shrinkwrap plus plastic
banding, only shrinkwrap, or only banding material if they can stay
together during normal processing. Except for packages of individually
polywrapped pieces, packages on BMC pallets must be shrinkwrapped and
machinable on BMC parcel sorters. Packages and bundles of individually
polywrapped pieces may be secured with banding material only.
Machinability is determined by the USPS. If used, banding material must
be applied at least once around the length and once around the girth;
wire and metal strapping are prohibited.
[Revise the first sentence of redesignated 1.6 to indicate that
packages of Bound Printed Matter must also meet the applicable maximum
package size standards in M045 and M722 to read as follows. No other
changes to text.]
1.6 Package Size--Bound Printed Matter
Each ``logical'' package (the total group of pieces for a package
destination) of Bound Printed Matter must meet the applicable minimum
and maximum package size standards prescribed in M045 or M722. * * *
1.7 Package Size--Other Mail Classes
Except for Bound Printed Matter, an individual package may be
prepared with fewer than the minimum number of pieces required by the
standards for the rate claimed without loss of rate eligibility under
either of these conditions:
a. A greater number of pieces would exceed the maximum physical
size for a package and the total number of pieces for that presort
destination meets the minimum volume standard (e.g., 30 pieces are
available to meet a 10-piece minimum, but a package of eight pieces is
6 inches thick).
b. The pieces constitute the ``last package'' for a presort
destination and previously prepared packages met the applicable minimum
volume standard (e.g., 505 pieces prepared in 10 50-piece packages and
one five-piece package)
[Redesignate former 1.7 as 1.9 and add new 1.8 to read as follows:]
1.8 Packages in Sacks--Periodicals and Standard Mail
Periodicals and Standard Mail prepared in sacks must be secured in
packages as follows:
a. The maximum weight for all packages is 20 pounds.
b. Packages up to 1 inch in height (thickness) must be secured with
appropriate banding, placed at least once around the girth (narrow
dimension), or with shrinkwrap. Packages over 1 inch in height must be
secured with at least two bands (plastic bands, rubber bands, or twine/
string), one around the length and one around the girth, with
shrinkwrap, or with shrinkwrap plus one or two bands.
c. Packages should be measured at the lowest (thinnest) point to
determine the package height.
d. A package that exceeds the maximum prescribed height by less
than the thickness of a single piece meets the standard (e.g., if a
glossy piece is 0.625 (\5/8\) of an inch thick, five pieces may be
secured in a package 3.125 inches high; if a piece with uncoated cover
stock is 0.75 (\3/4\) of an inch thick, 11 pieces may be secured in a
package 8.25 inches high).
[[Page 29040]]
e. Packages of pieces with covers of coated stock that are not
individually enclosed in a mailing wrapper (e.g., magazines or catalogs
with glossy covers not individually enclosed in an envelope, uncoated
paper wrapper, or plastic wrapper (polybag)) are subject to these
conditions:
(1) Except as noted in e(2), packages must not exceed 3 inches in
height (thickness).
(2) Packages of such pieces secured with shrinkwrap plus one or two
plastic straps, or with at least two plastic straps, one around the
length and one around the girth, must not exceed 6 inches in height
(thickness).
f. Packages containing pieces with outer surfaces of uncoated stock
are subject to these conditions:
(1) ``Uncoated stock'' also refers to pieces with coated covers
that are individually enclosed in a cover or mailing wrapper of
uncoated stock such as an envelope, sleeve, protective cover, partial
wrapper, or polybag and pieces with outer surfaces composed of material
other than paper (e.g., plastic, cloth, fiberboard, or metal).
(2) Packages must not exceed 8 inches in height (thickness);
however, it is recommended that such packages not exceed 6 inches in
height (thickness).
[Amend the heading of redesignated 1.9 to read as follows. No other
changes to text.]
1.9 Exception to Package Preparation--Mail in Trays
* * * * *
2.0 ADDITIONAL STANDARDS--FIRST-CLASS MAIL, PERIODICALS, AND STANDARD
MAIL, AND FLAT-SIZE BOUND PRINTED MATTER
[Amend 2.1 by copying the content of 2.3b to new 2.1f and revising
the content to read as follows:]
2.1 Cards and Letter-Size Pieces
Cards and letter-size pieces are subject to these packaging
standards:
* * * * *
f. Packages up to 1 inch thick must be secured with appropriate
banding placed once around the girth (narrow dimension). Packages over
1 inch thick must be secured with at least two bands, one around the
length and one around the girth.
[Amend 2.2 by revising the content to read as follows:]
2.2 Flat-Size Pieces
Packages of flat-size pieces must be secure and stable subject to
specific weight limits in M045 if placed on pallets, specific weight
and height limits in 1.8 for Periodicals and Standard Mail placed in
sacks, and, for Bound Printed Matter in sacks, specific weight limits
in M720. Flat-size pieces must be prepared in packages except under 1.9
and, for First-Class Mail, under M820.3.0.
[Amend the heading of 2.3 and amend the content by copying and
amending 2.3a and deleting current 2.3b to read as follows:]
2.3 Pieces With Simplified Address
For mail prepared with a simplified address, all pieces for the
same post office must be prepared in packages of 50 when possible. If
packages of other quantities are prepared, the actual number of pieces
must be shown on the facing slip attached to show distribution desired
(e.g., rural route, city route, post office boxholder). Packages must
be secure and stable subject to specific weight limits in M045 if
placed on pallets, specific weight and height limits in 1.8 for
Periodicals and Standard Mail placed in sacks, specific thickness
limits in 2.1 for cards and letter-size pieces, and, for Bound Printed
Matter in sacks, specific weight limits in M720.
* * * * *
Stanley F. Mires,
Chief Counsel, Legislative.
[FR Doc. 01-13397 Filed 5-25-01; 8:45 am]
BILLING CODE 7710-12-P