Rule changes expand tub use: car-rt, non-auto

July 3, 2013

NNA sought both, one since 2006

By Max Heath

The U.S. Postal Service issued two rule changes sought by the National Newspaper Association that expand the ability of newspapers to use flats trays (white tubs) for all presorted copies not dropped at the office of delivery. Both were in the Postal Bulletin of May 30, pages 5-7.

Both are effective July 28, 2013, and change language in Domestic Mail Manual sections 707 and 705. Flats trays are specifically allowed as an optional use by DMM 707.20.4 since 2006.



The first of the two changes, this one sought by NNA for several years, allows carrier-route bundles in flats trays. NNA had asked for it in 2006 when the tub rules were being expanded to all presort levels, and we provided information to support our case from certain postal processing plant personnel. Plants told NNA that carrier-route bundles of newspapers were usually sent from the plant directly to the 5-digit post office for handling. 

To our disappointment, the final rule omitted carrier-route bundles. We were later told that the powers that be wanted rules to be identical across the board, and this “exception” wasn’t allowed. 

In succeeding years, we learned that many, if not most, PAVE-certified software vendors didn’t allow it, keeping flats trays from being used in a mailing where small bundles of carrier-routed mail would have gone in containers destined to 5-digit, 3-digit, or SCF destinations in areas surrounding a newspaper’s primary market area.  

NNA’s Postal Committee talked to staff in Operational Requirements & Integration repeatedly in recent years about the need to allow carrier-route bundles in flats trays, but to no avail. We were working on the issue in a newly formed Mail Prep & Entry work group under the Mailers Technical Advisory Committee. (NNA was once again the only representative of unbound newspapers speaking up for your interests.)



Then we got a break that elevated the issue to higher authority. A bulk mail clerk in Cleveland invoked an obscure rule two clicks deep into the DMM flats tray section that prohibited nonmachinable copies. The Attica Hub, an NNA member in Ohio, was the victim. NNA had never before seen this enforced. But there it was, in black and white.

NNA brought the problem to Bill Chatfield in Product Classification, and Chuck Tricamo, periodicals specialist and acting manager in the Pricing & Classification Service Center in New York City. Chatfield agreed to work on a fix if there was a “sponsor” for the issue in top management, and Tricamo told Cleveland to hold up enforcement while the matter was being considered.

This emergency problem in Cleveland led to NNA teaming the two issues together. Although not a widespread enforcement problem like the carrier-route bundles, it added urgency to fix both.


Headquarters PROCESSING Manager WANTS


Linda Marie Malone, manager of Processing in USPS HQ, met with NNA at the February MTAC meeting. She affirmed that for more efficient and timely processing, their plants needed all newspapers in trays, not sacks. She said she was happy to “sponsor” the rule change not only for nonmachinable newspapers but also to allow carrier-route bundles in trays. 

It took three months to get the issue worked through USPS headquarters building, but Chatfield did a masterful job of wordsmithing that should leave no doubt for software vendors or postal clerks that read the language. The notice was entitled “Expansion of Optional Use of Flats Trays for Periodicals Flats.”

Mailers may use the options immediately, if possible, or when software vendors reprogram, worst case. NNA members should feel free to share this info with their preferred vendor to ensure it’s not overlooked.

I also want to share a few key DMM citations that NNA members should save to show postmasters if needed:

DMM 705.10.1, Advanced Preparation … now says “Throughout 10.1, trays may be used in lieu of sacks, even when the language specifies just ‘sacks.’ ”

DMM 707.22.1.a is revised to say, among other things: “Machinable barcoded and nonbarcoded pieces may be cobundled together under 705.11.0.

DMM 707.22.1.4 is revised to say, “… nonbarcoded price 5-digit bundles … may be cotrayed with carrier route bundles …” 

DMM 707.22.7 is revised to say: “Mailers also may prepare nonmachinable flats in flat trays.”

(The optional tray prep is outlined in DMM 707.20.4, but nonbarcoded preparation rules are in 707.22.)



Chatfield also did NNA members a big favor by adding at the end of the Postal Bulletin notice DMM 707.23.4.2, “Exception to Sacking,” which clarifies that “Sacking or traying is not required for carrier-route or 5-digit bundles entered at a DDU when the mailer unloads bundles … (and) Mail presented under the latter exception is not subject to the container charge (but is subject to the bundle charge).

Flats Trays (tubs) should be used wisely, and only for presort mail not DDU-entered, as we said in the opening. It reserves trays for their highest and best use, and saves mailers cost of putting DDU-entered copies in containers, and USPS employees from taking them out. © Max Heath 2013


MAX HEATH, NNA Postal chair, is a postal consultant for Publishing Group of America (American Profile, Relish, & Spry) and Landmark Community Newspapers, LLC. Email

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